Hadzi-Tanovic v. Johnson

Dist. Ct. did not err in dismissing without prejudice plaintiff’s section 1983 and section 1985 actions, alleging that defendants-her ex-husband, her children’s guardian ad litem and state court judge conspired to violate her and her children’s rights to family association and her right to fair and unbiased trier of fact, when state court judge entered order that modified visitation schedule to require that all of plaintiff’s visitation time with her children be supervised. Record showed that plaintiff had appealed state court judge’s order to appellate court, and that appellate dismissed her appeal after plaintiff had failed to file her opening brief. Plaintiff then filed instant action after dismissal of her appeal. Ct. of Appeals held that Rooker-Feldman doctrine applied to deprive Dist. Ct. of jurisdiction to resolve plaintiff’s claims, since: (1) allegations in federal complaint asserted that state court judgment caused plaintiff’s injuries at issue in instant federal case; and (2) analyzing plaintiff’s allegations of corruption would require federal court to improperly review propriety of final state court judgment, which only U.S. Supreme Court can do. Ct. of Appeals also overruled prior decisions that held that Rooker-Feldman doctrine did not apply, where plaintiff presents claim that state court judge was corrupt in rendering decision at issue in federal lawsuit. (Dissent filed.)