Woosley v. United States District Court for the District of Connecticut, 693 F. App'x 144

Background

Woosley is the biological father whose parental rights were terminated in Texas after he signed an Affidavit of Waiver shortly after his son’s 1992 birth; the Smiths subsequently adopted the child.
Woosley has repeatedly sought to challenge the termination/adoption since 1993 in multiple state and federal courts; prior suits were dismissed on various preclusion and statute-of-limitations grounds.
In 2003 the District of Connecticut entered an injunction barring Woosley from relitigating the validity of the Texas decrees; the Second Circuit in 2005 modified that injunction to allow suits only if (1) a limitations period remained open, (2) personal jurisdiction over defendants could be obtained, and (3) a viable claim existed.
In 2010 Woosley violated the Connecticut injunction by filing a Petition to Void Adoption in Pennsylvania, later withdrawing it after a Connecticut judge ordered him to do so; he then filed this Bivens-style § 1983 suit in the Eastern District of Pennsylvania against the District of Connecticut, Judge Thompson, and the Smiths seeking $22 million.
The district court dismissed for lack of Article III standing (and alternatively on immunity and sanction grounds); the Third Circuit affirmed, holding Woosley lacked a legally cognizable injury fairly traceable to the defendants and thus lacked jurisdiction.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Article III standing to challenge the Connecticut injunction	Woosley: the injunction violated his fundamental right to child custody and prevented him from seeking recognition as the child’s legal father	Defendants: res judicata, statutes of limitations, and the injunction together mean any injury is not caused by defendants and claims are time‑barred	Court: No standing — Woosley has no legally protected interest in filing frivolous/time‑barred suits; alleged injury not fairly traceable to defendants
Causation / Traceability	Woosley: preclusion doctrines don’t apply to void judgments; injunction caused his inability to obtain legal recognition	Defendants: any bar to relief stems from prior state judgments and statutes of limitations, not the injunction	Held: Injury stems from the underlying termination and time limits, not the injunction or defendants’ conduct
Redressability / Mootness (effect of son reaching majority)	Woosley: declaratory/monetary relief would vindicate status and aid relationship with adult son	Defendants: relief would not likely restore parental status or meaningful relationship; claims are moot or nonredressable	Held: Redress is speculative; even if standing existed, claims lack substantive merit
Alternative defenses (judicial immunity; §1983 inapplicability)	—	Defendants: Judge Thompson is immune; §1983 does not apply to federal actors (Bivens context); adoptive parents not proper §1983 defendants	Held: District court’s alternative rulings (immunity and §1983 inapplicability) support dismissal, though the Third Circuit affirmed on standing grounds

Key Cases Cited

Smith v. Woosley, 399 F.3d 428 (2d Cir. 2005) (modifying Connecticut injunction and setting conditions for relitigation)
Common Cause of Pa. v. Pennsylvania, 558 F.3d 249 (3d Cir. 2009) (standing governs federal subject‑matter jurisdiction)
White‑Squire v. U.S. Postal Serv., 592 F.3d 453 (3d Cir. 2010) (federal courts determine their own jurisdiction)
Becton Dickinson & Co. v. Wolckenhauer, 215 F.3d 340 (3d Cir. 2000) (appellate jurisdiction under §1291 review of jurisdictional rulings)
Schmidt v. Skolas, 770 F.3d 241 (3d Cir. 2014) (courts may consider public records and exhibits on facial standing review)
Woosley v. Smith, 191 F.3d 446 (3d Cir. 1999) (affirming dismissal as time‑barred)
Sprint Comm’ns Co. v. APCC Servs., Inc., 554 U.S. 269 (2008) (standing requires injury, causation, redressability)
Bivens v. Six Unknown Named Agents, 403 U.S. 388 (1971) (establishing personal‑capacity damages remedy against federal officers)