Steeprow v. Property & Casualty Insurance Company of Hartford
6:16-cv-00215
| M.D. Fla. | Sep 30, 2016Background
- Pro se plaintiff Kenneth G. Steeprow sued 27 defendants arising from a January 28, 2010 car accident and related state-court proceedings, seeking substantial compensatory and punitive damages.
- Complaint alleges a "race hate conspiracy" and that defendants’ actions and state-court rulings caused physical and mental injuries and financial harm.
- Plaintiff filed an application to proceed in forma pauperis; Magistrate Judge David A. Baker issued an R&R recommending denial of that motion and dismissal for lack of jurisdiction under the Rooker–Feldman doctrine.
- Magistrate Judge concluded Steeprow’s claims seek redress for injuries that are causally tied to and would require overturning state-court judgments.
- District Court conducted de novo review, overruled plaintiff’s objection, adopted the R&R, denied IFP status, dismissed the complaint for lack of subject-matter jurisdiction, and closed the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the federal court has jurisdiction over claims that attack state-court decisions | Steeprow contends he does not seek reversal of state-court rulings and seeks independent damages for conspiratorial conduct | Defendants (via R&R) argue plaintiff's claims are inextricably intertwined with state-court judgments and thus barred | Court held Rooker–Feldman bars jurisdiction because relief would effectively require finding state judgments incorrect |
| Whether claims seeking damages for injuries caused by state-court proceedings can proceed in federal court | Steeprow asserts harms are separate and not an attempt to nullify state judgments | Rooker–Feldman prevents federal review of state-court losers’ attempts to relitigate or nullify state decisions | Court held damages claims arise from state rulings and are barred; dismissal warranted |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Sup. Ct. 2005) (articulates Rooker–Feldman bar to federal district review of state-court judgments)
- Casale v. Tillman, 558 F.3d 1258 (11th Cir. 2009) (clarifies when claims are "inextricably intertwined" with state-court decisions)
- Jeffrey S. v. State Bd. of Educ. of State of Ga., 896 F.2d 507 (11th Cir. 1990) (discusses de novo review standard for magistrate judge recommendations)