Tyler v. Supreme Judicial Court of Mass.Tyler v. Supreme Judicial Court of Mass.
Wendy Murphy for appellant.
Todd M. Blume, Assistant Attorney General, Criminal Bureau, with whom Maura Healy, Attorney General, was on brief, for appellees.
I.
In 2009, at age nineteen or twenty, Jamie Melendez impregnated fourteen-year-old Heather Tyler.2 Tyler gave birth in 2010. Upon pleading guilty in state court to the statutory rape of Tyler, Melendez received a sentence of sixteen years of probation. As conditions of probation, the sentencing judge ordered Melendez to acknowledge paternity of the child and abide by all orders of the Massachusetts Probate and Family Court.
In August 2012, after learning that Melendez sought to obtain parental visitation rights in the Probate and Family Court, Tyler filed a motion with the criminal sentencing judge seeking reversal of the conditions of probation mentioned above. She objected to the conditions on the grounds that Melendez‘s compliance with them would bind her to an unwanted sixteen-year legal relationship with Melendez in the Probate and Family Court. She requested that Melendez instead pay criminal
Tyler then filed an action under the Federal Civil Rights Act,
In November 2013, Tyler filed a motion in the Probate and Family Court seeking either to vacate the court‘s jurisdiction or to terminate Melendez‘s parental rights. She contended that an adult convicted of statutory rape should have no parental rights with respect to a child born as a result of that crime. After the family court denied her motion, Tyler sought review in the Appeals Court of Massachusetts. The Appeals Court affirmed, holding that “nothing in the language of [the family court statute,
amendment‘s] language that it was designed to limit, rather than to expand, the court‘s existing authority,” the statute must have previously authorized family courts to adjudicate the parental rights of a parent convicted of statutory rape. Id. Finally, the Appeals Court denied Tyler‘s plea to vacate jurisdiction as a matter of public policy, noting that “the mother‘s desired disposition [would] require us to treat the father more favorably than other biological fathers, [and] it also would unfairly disadvantage the child by depriving her of the right to receive financial support from both parents.” Id. at *3. In 2017, the SJC denied Tyler‘s application for further appellate review. See H.T. v. J.M., 75 N.E.3d 1130 (Mass. 2017).
“The Rooker-Feldman doctrine prevents consideration because [Tyler] present[s] a dispute brought by an unsuccessful litigant in the state courts seeking to have a lower federal court review and reject a state court judgment rendered before the federal litigation commenced.” Tyler v. Supreme Judicial Court of Mass., 292 F. Supp. 3d 555, 556 (D. Mass. 2018) (footnote omitted).
This appeal followed.
II.
Under the Rooker-Feldman doctrine, “lower federal courts are precluded from exercising appellate jurisdiction over final state-court judgments.” Lance v. Dennis, 546 U.S. 459, 463 (2006). The idea is that -- absent exceptions not present here -- the only federal court with statutory jurisdiction to review a state court‘s decision is the Supreme Court, and “an aggrieved litigant cannot be permitted to do indirectly what he no longer can do directly.” Rooker, 263 U.S. at 416. The Rooker-Feldman doctrine bars jurisdiction “only in the ‘limited circumstances’ where ‘the losing party in state court filed suit in federal court after the state proceedings ended, complaining of an injury caused by the state-court judgment and seeking review and rejection of that judgment.‘” Federación de Maestros de P.R. v. Junta de Relaciones del Trabajo de P.R., 410 F.3d 17, 23-24 (1st Cir. 2005) (quoting Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 291 (2005)).
The record makes plain that Tyler came to federal court seeking an end-run around the SJC‘s 2017 decision allowing the Probate and Family Court to adjudicate Melendez‘s parental rights. Tyler‘s brief to this court concedes that her complaint “asks the federal court to reverse the state court judgment.” And the complaint does indeed request that the district court “[d]eclar[e] the Supreme Judicial Court‘s decision unconstitutional.” The complaint also repeatedly identifies the SJC‘s 2017 decision as the exclusive cause of Tyler‘s injury. After discussing the state-court proceedings culminating with the denial of her application for further appellate review “by the Supreme Judicial Court on January 26, 2017,” Tyler details three counts all challenging that decision. Count I alleges that the “ruling threatens Plaintiff‘s rights by exposing Plaintiff to an unlawful restraint on her liberty and a seizure of her person“; Count II alleges that the “ruling threatens Plaintiff‘s liberty and privacy“; and Count III alleges that the “decision violates Plaintiff‘s equal protection rights.” “Where federal relief can only be predicated upon a conviction that the state court was wrong, it is difficult to conceive the federal proceeding as, in substance, anything other than a prohibited appeal of the state-court judgment.” Hill v. Town of Conway, 193 F.3d 33, 39 (1st Cir. 1999) (quoting Pennzoil Co. v. Texaco, Inc., 481 U.S. 1, 25 (1987) (Marshall, J., concurring)).
Tyler seeks haven from the application of this doctrine by arguing that, “[a]lthough [she] raised the federal issues
Tyler counters that we should read the state court‘s statement that her contentions did not require discussion to mean that the state court believed that it lacked standing to entertain her federal claims on the merits. Hence, she argues, the state court arrived at no final judgment susceptible to challenge or “end-run.” We cannot agree. As the Appeals Court‘s opinion itself notes, the 2013 SJC opinion rejecting for lack of standing Tyler‘s
attempt to intervene in the criminal proceeding declared that Tyler would have standing to assert her claims in an appeal from an order of the Family and Probate Court. See H.T. v. Commonwealth, 989 N.E.2d at 426; H.T. v. J.M., 2016 WL 7046435, at *1 (“The [SJC] explained . . . that it remained open to the mother to raise any claim of error in the ordinary appellate process from proceedings in the Probate and Family Court.“). It would therefore make no sense to interpret the Appeals Court‘s opinion in the appeal arising out of the Probate and Family Court proceedings as incorporating the SJC‘s standing analysis from the prior criminal case, barring her from taking the precise action blessed by the SJC. Besides, Tyler has given us no reason to believe that her standing was even contested in either the Appeals Court case or the 2017 SJC appeal. We therefore read the Appeals Court‘s footnote to mean that it reached Tyler‘s federal constitutional claims and summarily rejected them on their merits. So, when the SJC declined to review the Appeals Court‘s decision, the state-court system ruled finally on Tyler‘s constitutional claims.
This analysis also disposes of Tyler‘s alternative argument: that she is not seeking a reversal of the state-court judgment, but rather presenting an independent, “general challenge to the constitutionality of state law.” It is true that the Rooker-Feldman doctrine does not bar a “general attack on the constitutionality” of a state law that “do[es] not require review
of a judicial decision in a particular case.” Feldman, 460 U.S. at 487. “‘If a federal plaintiff “presents an independent claim,“’ it is not an impediment to the exercise of federal jurisdiction that the ‘same or a related question’ was earlier aired between the parties in state court.” Skinner v. Switzer, 562 U.S. 521, 532 (2011) (alterations omitted) (quoting Exxon Mobil Corp., 544 U.S. at 292-93). But that exception does not apply “if the relief sought in federal court is directed towards undoing the prior state judgment.” Maymó-Meléndez v. Álvarez-Ramírez, 364 F.3d 27, 34 (1st Cir. 2004). As we have explained, the relief Tyler seeks is entirely predicated on her insistence that the SJC erred in the 2017 adjudication of her case. Her attempt to reframe the case as an independent challenge to the Massachusetts law is therefore “felled by [her] own
Finally, Tyler argues that “the state proceedings have not ended with regard to the federal issues [she] seeks to have reviewed in federal court.” See Exxon Mobil Corp., 544 U.S. at 291 (holding that the Rooker-Feldman doctrine only applies when the losing party in state court files suit in federal court “after the state proceedings ended“). In connection with this argument, she observes that her family court matters “will remain pending for at least another ten years.” But she offers no suggestion that the family court will ever reconsider the federal claims she
presses here. See Federación de Maestros, 410 F.3d at 25 (observing that state proceedings have ended for purposes of the Rooker-Feldman doctrine when “the state court proceedings have finally resolved all the federal questions in the litigation, but state law or purely factual questions . . . remain to be litigated“).
In sum, Tyler is a “losing party in state court [who] filed suit in federal court after the state proceedings ended, complaining of an injury caused by the state-court judgment and seeking review and rejection of that judgment.” Federación de Maestros, 410 F.3d at 24 (quoting Exxon Mobil Corp., 544 U.S. at 291). The district court therefore correctly held that it lacked jurisdiction to hear Tyler‘s claims.
III.
For the foregoing reasons, we affirm the district court‘s dismissal for want of jurisdiction.