Watkins v. State of California, 4:18-cv-07496

Plaintiff Raymond C. Watkins, a pretrial detainee at Napa State Hospital, alleges custodial staff are forcibly administering psychiatric medication that impairs his ability to communicate with counsel and participate in his defense.
Tuolumne County Superior Court found Watkins incompetent to stand trial and on August 6, 2018 suspended his criminal proceedings, committed him to Napa State Hospital under Cal. Penal Code § 1370, and authorized involuntary medication pursuant to Sell v. United States.
Watkins filed a pro se civil-rights action under 42 U.S.C. § 1983 seeking to stop the involuntary medication; he names the State of California as defendant.
The State moved to dismiss under Rules 12(b)(1) and 12(b)(6), arguing among other things that the federal court lacks subject-matter jurisdiction under the Rooker–Feldman doctrine and that the complaint fails to name a proper defendant or plead sufficient facts.
The district court took judicial notice of the state-court order, found Watkins’s claims amount to a de facto appeal of that order, and GRANTED the motion to dismiss for lack of subject-matter jurisdiction; it did not reach the 12(b)(6) arguments.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Federal jurisdiction under Rooker–Feldman	Watkins seeks federal relief from state-court competency/medication order	Federal courts lack jurisdiction to review state-court judgments	Court: Rooker–Feldman bars jurisdiction; dismissal granted
Proper form of action (§1983 vs habeas)	Watkins asserts he intended a state habeas, or alternatively brings constitutional claims	Defendant treats it as §1983 challenging state-court order	Court: Will not convert to habeas; §1983 challenge to state order is barred by Rooker–Feldman
Merits of involuntary medication (due process / Sell)	Medication violates liberty, free speech, religious freedom, and impairs defense	State relies on prior state-court authorization under Sell and commitment statutes	Court: Did not reach merits due to lack of jurisdiction
Parties and pleading sufficiency	Watkins alleges harms but procedurally confused; contends appeals blocked	State contends wrong defendant and insufficiently particular facts	Court: Declined to address these arguments after finding lack of jurisdiction

Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (federal district courts may not exercise appellate jurisdiction over state-court decisions)
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (Rooker–Feldman bars lower federal court review of state court judgments)
Sell v. United States, 539 U.S. 166 (2003) (permissive standard for involuntary antipsychotic medication to restore competence under limited circumstances)
Kougasian v. TMSL, Inc., 359 F.3d 1136 (9th Cir. 2004) (Rooker–Feldman bars de facto appeals to district court)
Branson v. Nott, 62 F.3d 287 (9th Cir. 1995) (Rooker–Feldman applies even when federal constitutional issues are raised)
Trimble v. City of Santa Rosa, 49 F.3d 583 (9th Cir. 1995) (district court should not convert a defective §1983 claim into a habeas petition)