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Staley v. Ledbetter

United States Court of Appeals, Eleventh Circuit
Feb 17, 1988
837 F.2d 1016 (11th Cir. 1988)

Summary

holding that a district court lacked jurisdiction to review a county agency's decision that had been upheld by the state court of appeals

Summary of this case from Ramos v. Tomasino

Opinion

No. 87-8025. Non-Argument Calendar.

February 17, 1988.

Patricia G. Staley, Waycross, Ga., for plaintiff-appellant.

William M. Droze, Atlanta, Ga., for defendants-appellees.

Appeal from the United States District Court for the Southern District of Georgia.

Before KRAVITCH, JOHNSON and EDMONDSON, Circuit Judges.


This appeal contests the district court's dismissal of plaintiff's civil rights action. Patricia G. Staley filed this action pursuant to 42 U.S.C. § 1983, seeking to challenge defendants' child custody determinations. She requested reinstatement of parental custody and psychiatric care at state expense for her children and herself. The district court dismissed Staley's complaint. Staley now appeals the dismissal and seeks "immediate habeas corpus relief." Today, we affirm the district court's judgment and deny Staley's request for relief.

Mrs. Staley and her husband, Edward Staley, adopted a girl and two boys through the DeKalb County Department of Family and Children Services ("DeKalb County DFACS"). Following an investigation in 1984, the DeKalb County DFACS placed the children in emergency foster care: Mr. Staley had sexually abused the children. Numerous hearings were held regarding the disposition of the children; a juvenile court adjudicated the children "deprived"; a termination of parental rights hearing was held; the juvenile court confirmed the termination plan; the court of appeals affirmed the juvenile court's judgment; and, finally, the Georgia Supreme Court denied the Staleys' writ of certiorari. In re A.T., 179 Ga. App. 879, 348 S.E.2d 110 (1985), cert. denied, (Sept. 2, 1986).

Mr. Staley confessed that he had sexually abused the children. Evidence gathered at the state agency hearings and juvenile court adjudication indicated that Mrs. Staley did little to stop the ongoing abuse. See In re A.T., 179 Ga. App. 879, 348 S.E.2d 110 (1986), cert. denied, (Sept. 2, 1986).

Mrs. Staley brought the present action pursuant to 42 U.S.C. sec. 1983, alleging violations of her civil rights under the Equal Protection and Due Process Clauses of the Fourteenth Amendment to the Constitution; and for violations of the Child Welfare Act of 1980, Pub.L. 96-272, 94 Stat. 500. The district court dismissed Staley's complaint. This appeal followed; Staley also filed a motion for "immediate habeas corpus relief."

Mrs. Staley drafted her complaint and filed this action without the aid of an attorney. Our description of this cause of action constitutes a liberal interpretation of her complaint.

We need not address the parties' substantive contentions, because no federal subject matter jurisdiction existed in this case. In effect, Staley seeks to challenge collaterally the state agency and court proceedings that terminated her parental rights. The federal courts are not a forum for appealing state court decisions. See District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 482-86, 103 S.Ct. 1303, 1315-17, 75 L.Ed.2d 206 (1983). Because "federal review of state court decisions is entrusted solely to the Supreme Court, [the lower federal courts] may not decide federal issues that are raised in state proceedings and `inextricably intertwined' with the state court's judgment." Wood v. Orange County, 715 F.2d 1543, 1546 (11th Cir. 1983), cert. denied, 467 U.S. 1210, 104 S.Ct. 2398, 81 L.Ed.2d 355 (1984). This "bar" also "operates where the plaintiff fails to raise his federal claims in state court." Id.

The district court in this case lacked jurisdiction to hear a sec. 1983 claim that in essence sought to reverse a state court's child custody determination. See Anderson v. State of Colorado, 793 F.2d 262, 263-65 (10th Cir. 1986). Accordingly, the district court's dismissal of Staley's complaint is AFFIRMED.

Likewise, Staley's request for habeas corpus relief must be denied, because "[ 28 U.S.C. § 2254] does not confer federal court jurisdiction" over challenges to state court child custody proceedings. Lehman v. Lycoming Co. Children's Services, 458 U.S. 502, 516, 102 S.Ct. 3231, 3240, 73 L.Ed.2d 928 (1982).

We decline to impose sanctions or award attorney's fees against Staley.


Summaries of

Staley v. Ledbetter

United States Court of Appeals, Eleventh Circuit
Feb 17, 1988
837 F.2d 1016 (11th Cir. 1988)

holding that a district court lacked jurisdiction to review a county agency's decision that had been upheld by the state court of appeals

Summary of this case from Ramos v. Tomasino

holding that a district court lacked jurisdiction to review a decision of a county agency, where that decision had been upheld by the state court of appeals

Summary of this case from Narey v. Dean

holding district court lacked jurisdiction to review a county agency's decision that had been upheld by the state court of appeals

Summary of this case from Demetrius Yvonne Parks v. Ala. Bd. of Pharmacy

holding that the Rooker Feldman doctrine bars federal district courts from reviewing a state court's child custody determination

Summary of this case from Hyde-Rhodes v. Crowley

holding that "no federal subject matter jurisdiction existed ... [because, in] effect, Staley seeks to challenge collaterally the state agency and court proceedings that terminated her parental rights"

Summary of this case from Jackson v. Dep't of Human Res.

holding that Rooker-Feldman deprived district court of jurisdiction over plaintiff's section 1983 claim in which she requested reinstatement of parental custody based on alleged violations of the Equal Protection and Due Process Clauses of the Fourteenth Amendment, because plaintiff "in essence sought to reverse a state court's child custody determination"

Summary of this case from Bobo v. Tulare Cnty.

holding that the Rooker-Feldman doctrine deprived the federal district and appellate courts of subject matter jurisdiction over a plaintiff's § 1983 claim based on alleged violations of the Equal Protection and Due Process Clauses of the Fourteenth Amendment that "in essence sought to reverse a state court's child custody determination"

Summary of this case from Noor v. Hickenlooper

finding court had no subject matter jurisdiction over parent's civil rights action which challenged state's child custody determination on due process and other grounds

Summary of this case from Miller v. Fla. Dep't of Children & Families

finding that the district court lacked subject-matter jurisdiction over the plaintiff's challenge of a state court proceeding terminating the plaintiff's parental rights and stating that "federal courts are not a forum for appealing state court decisions"

Summary of this case from Johnson v. Hillsborough Cnty. Circuit Court

concluding that we lacked subject-matter jurisdiction under the Rooker-Feldman doctrine to consider a party's section 1983 claim that "in essence sought to reverse a state court's child custody determination"

Summary of this case from Drees v. Ferguson

affirming the district court's dismissal of section 1983 complaint asserting claims of due process violations for lack of jurisdiction where plaintiff sought "reinstatement of parental custody and psychiatric care at state expense for her children and herself"

Summary of this case from Sosnowski v. Xeureb

affirming dismissal of § 1983 action challenging child custody determinations

Summary of this case from Thompson v. McFatter

In Staley, for example, we held that the Rooker-Feldman doctrine deprived the district court of jurisdiction over a plaintiff's 42 U.S.C. § 1983 claim in which "[s]he requested reinstatement of parental custody and psychiatric care at state expense for her children and herself" based on alleged violations of the Equal Protection and Due Process Clauses of the Fourteenth Amendment.

Summary of this case from Fox v. Fla. Dep't of Children & Families

In Staley, we held that the Rooker-Feldman doctrine deprived the district court and this Court of jurisdiction over a plaintiff's § 1983 claim in which "[s]he requested reinstatement of parental custody and psychiatric care at state expense for her children and herself" based on alleged violations of the Equal Protection and Due Process Clauses of the Fourteenth Amendment. 837 F.2d at 1017.

Summary of this case from Goodman ex Rel. Goodman v. Sipos

In Staley, the adoptive mother first sought to regain custody of her child in the Georgia state court system, but lost in the juvenile court, the state court of appeals, and in the state supreme court.

Summary of this case from Jefferson v. Slaughter

In Staley, a former adoptive mother filed a civil rights action against the Georgia Commissioner of Human Resources seeking to challenge child custody determinations and termination of her parental rights on grounds of equal protection and due process violations. 837 F.2d at 1017.

Summary of this case from Comstock v. Hooban

In Staley, a former adoptive parent brought a civil rights action against the Georgia Commissioner of Human Resources alleging equal protection and due process violations in connection with termination of his parental rights.

Summary of this case from Cooper-Jolley v. Lyttle
Case details for

Staley v. Ledbetter

Case Details

Full title:PATRICIA G. STALEY, PLAINTIFF-APPELLANT, v. JAMES G. LEDBETTER…

Court:United States Court of Appeals, Eleventh Circuit

Date published: Feb 17, 1988

Citations

837 F.2d 1016 (11th Cir. 1988)

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