Speight v. Kaelblein
1:24-cv-12363
D. Mass.May 16, 2025Background
- Michael Sean Speight III (pro se) filed a § 1983 action against Amanda Kaelblein (mother of his child), her parents (Michael and Nancy Kaelblein), and Eric Stephan (Massachusetts DOR attorney), alleging constitutional violations in connection with Massachusetts Probate and Family Court child custody and support proceedings.
- The disputed events stem from Amanda relocating their child from New Hampshire to Massachusetts in May 2022, followed by competing court actions regarding custody and support in both states.
- Speight alleges that Attorney Stephan improperly issued a child support order contrary to a judge’s instruction, and that the Kaelbleins supported false statements and interfered with Speight’s relationship with his child.
- Claims include requests for damages (emotional, financial, punitive) and declaratory relief based on alleged due process and equal protection violations.
- The case was originally filed in New Hampshire federal court, later transferred to Massachusetts. Defendants moved to dismiss for lack of jurisdiction and failure to state a claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal court jurisdiction over domestic relations matters | Claims proper under § 1983; not interfering with custody/support | Domestic relations exception bars federal review of child custody/support (state court domain) | No federal jurisdiction or abstention is warranted |
| Rooker-Feldman/Younger doctrines' applicability | Not seeking review of state orders, only damages | Suit impermissibly challenges state court orders, barred by Rooker-Feldman/Younger | Barred by Rooker-Feldman or Younger doctrine |
| Immunity of state actors under § 1983 | State actor (Stephan) acted outside immunity; liable for damages | Stephan immune by Eleventh Amendment (official capacity) and as prosecutor (individual) | Immunity bars claims against Stephan |
| Adequacy of § 1983 conspiracy pleadings against private parties | Defendants conspired with state actor, violating rights | Allegations are conclusory, lack specific facts linking private defendants to state conspiracy | Complaint fails to state a claim, dismissed |
Key Cases Cited
- Ankenbrandt v. Richards, 504 U.S. 689 (domestic relations exception to federal court jurisdiction is narrow, mostly for divorce, alimony, child custody decrees)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards: complaint must be plausible, not just conclusory)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (complaints require more than naked assertions to survive dismissal)
- Will v. Michigan Dept. of State Police, 491 U.S. 58 (states and state officials in official capacity are not "persons" under § 1983)
- Younger v. Harris, 401 U.S. 37 (federal courts abstain from interfering with ongoing state proceedings)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal district courts cannot act as appellate courts for state court judgments)
- Sutter v. Pitts, 639 F.2d 842 (domestic relations actions clothed as civil rights suits still fall outside federal jurisdiction)