PHILADELPHIA – Per a recent decision from the U.S. Court of Appeals for the Third Circuit, a civil lawsuit filed against the Domestic Relations Compliance Unit of the Montgomery County Court of Common Pleas remains dismissed.
In a per curiam ruling, Third Circuit judges Thomas L. Ambro, Joseph A. Greenaway Jr. and Leonard I. Garth decided Anthony Lamar Green’s suit alleging the DRCU violated his due process rights under the Fourteenth Amendment to the U.S. Constitution would not succeed.
Green filed a civil rights action under 42 U.S.C. Section 1983, in the U.S. District Court for the Eastern District of Pennsylvania against the DRCU, contending the organization was liable for “misapplying the Pennsylvania support rules and guidelines, the defendant violated his substantive and procedural due process rights under the Fourteenth Amendment.”
Green was sued by his wife for divorce in 2009, and argued he was not credited in a 2010 support order outlining mortgage payment calculations, which is mandated by Pennsylvania rules of civil procedure and related guidelines.
However, the DRCU filed a motion to dismiss for failure to state a claim, asserting the DRCU is not a “person” liable for suit under 42 U.S.C. Section 1983; that the Eleventh Amendment barred the suit; and that subject matter jurisdiction was lacking under the Rooker-Feldman doctrine, among other arguments.
The Rooker-Feldman doctrine states a federal court does not have jurisdiction to review decisions of state courts or claims “inextricably intertwined” with an earlier state court judgment.
The District Court eventually ruled in line with the defense’s argument, explaining “granting him relief would require the Court to determine that the state court judgment was invalid”, the precise circumstance that Rooker-Feldman prohibits.
Alternatively, the District Court believed Green’s claims were barred by the Eleventh Amendment, which precludes actions in federal court against the states, citing Coleman v. Court of Appeals of Maryland. Green timely appealed to the Third Circuit.
“The District Court correctly reasoned that subject matter jurisdiction is lacking in the federal district courts to the extent that Green sought review of the state court support order,” the Third Circuit said. “Accordingly, we also hold that, to the extent that Green’s civil rights action presented an independent non-barred claim, he failed to state a claim upon which relief may be granted.”
Further, the Third Circuit believed Green’s claims were in fact precluded by the Eleventh Amendment, which “immunizes Pennsylvania, its agencies, and its employees acting in their official capacities, from suits brought pursuant to 42 U.S.C. Section 1983 in federal court.”
“As explained by the District Court, none of the exceptions to Eleventh Amendment immunity applies here because Pennsylvania has not consented to suit in federal court, and the defendant, the Domestic Relations Section of the Montgomery County Court of Common Pleas, is a sub-unit of Pennsylvania’s unified judicial system,” the Third Circuit said. “All courts in the unified judicial system are part of the Commonwealth and are entitled to Eleventh Amendment immunity. Therefore, all claims against the Domestic Relations Section of the Montgomery County Court of Common Pleas were properly dismissed pursuant to its Eleventh Amendment immunity.”
The Third Circuit explained Green’s amended complaint, which only named the DRCU and had been filed in a timely manner, superseded his initial suit which named officers of the DRCU as defendants in their official and individual capacities.
“We note further that, although Rooker-Feldman holds that lower federal courts lack subject matter jurisdiction to engage in appellate review of state court determinations, Green may still have review of his constitutional claims in the Pennsylvania appellate courts, and, ultimately, in the Supreme Court of the United States under 28 U.S.C. Section 1257,” the Third Circuit said.
The appellee is represented by Martha Gale of the Administrative Office of Pennsylvania Courts, in Philadelphia.
U.S. Court of Appeals for the Third Circuit case 15-2036
U.S. District Court for the Eastern District of Pennsylvania case 2:15-cv-00105
From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at nickpennrecord@gmail.com