Andrew Podems v. Union County Child Support Enforcement Unit

CourtCourt of Appeals for the Third Circuit
DecidedApril 3, 2025
Docket24-1811
StatusUnpublished

This text of Andrew Podems v. Union County Child Support Enforcement Unit (Andrew Podems v. Union County Child Support Enforcement Unit) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Andrew Podems v. Union County Child Support Enforcement Unit, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 24-1811 __________

ANDREW M. PODEMS, Appellant

v.

NEW JERSEY DEPARTMENT OF JUSTICE, Civil Division, Family Part, Superior Appellate Court, Superior Court; UNION COUNTY CHILD SUPPORT ENFORCEMENT UNIT; THERESA E. MULLER, Hearing Officer; JAMES HELY, Hearing Officer; KONSTANTIN FELDMAN, Hearing Officer; LAURA GENECKI, Hearing Officer; HEARING OFFICERS DOE to be named after discovery ____________________________________

On Appeal from the United States District Court for the District of New Jersey (D.C. Civil Action No. 2:21-cv-04398) District Judge: Honorable Julien X. Neals ____________________________________

Submitted Pursuant to Third Circuit LAR 34.1(a) March 24, 2025 Before: BIBAS, FREEMAN, and NYGAARD, Circuit Judges

(Opinion filed April 3, 2025) ___________

OPINION* ___________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. PER CURIAM

Andrew Podems and Michele Piech married, moved from New Jersey to Alaska,

became parents, got divorced, then returned to New Jersey. The divorce spawned lengthy

litigation that has included applications for relief related to marital property, custody,

parenting time, and child support. See, e.g., Podems v. Piech, No. A-3243-22, 2024 WL

2933354 (N.J. Super. Ct. App. Div. June 11, 2024) (per curiam); Podems v. Podems, No.

S-15242, 2014 WL 1421968 (Alaska Apr. 9, 2014) (unpublished summary disposition).

According to Podems, the litigation has not only been expensive, but unfair.

Podems alleges that: he is owed more of Piech’s retirement-account earnings than has

been judicially determined; his requests to modify child support and parenting time have

been improperly denied by biased judges; his insurance proceeds from a car accident

were improperly levied upon; he was jailed for three days without due process after

failing to pay child support; and the New Jersey court system imposes hypertechnical

filing requirements and is, in general, rigged against impecunious litigants.

To address those perceived inequities, Podems filed this civil rights action.

Podems availed himself of multiple opportunities to try and plead viable claims while

proceeding pro se—his two motions requesting pro bono counsel having been denied by

the Magistrate Judge assigned to his case. Podems’s fourth amended complaint (the FAC)

named as defendants the New Jersey Judiciary, the family court’s child-support

enforcement arm, two judges, and two hearing officers (collectively, the Defendants).

2 The Defendants moved to dismiss the FAC under Federal Rules of Civil Procedure

12(b)(1) and 12(b)(6). Their arguments for dismissal centered on immunity doctrines.

The District Court declined to dismiss the FAC based on Podems’s serial non-

compliance with Federal Rule of Civil Procedure 10(b) (“A party must state its claims or

defenses in numbered paragraphs, each limited as far as practicable to a single set of

circumstances.”), in light of Podems’s pro se status.1 The District Court instead entered

an order granting the Defendants’ motion and dismissing the FAC under Rule 12(b)(1).

In its accompanying opinion, the District Court determined that Podems’s claims

failed to pierce the Defendants’ sovereign immunity under the Eleventh Amendment. The

District Court also determined that the non-entity defendants were entitled to either

judicial or quasi-judicial immunity. The District Court determined further that Podems

had not plausibly pleaded an exception to Eleventh Amendment immunity under Ex Parte

Young, 209 U.S. 123 (1908), “under which individual state officers can be sued in their

individual capacities for prospective injunctive and declaratory relief to end continuing or

ongoing violations of federal law,” MCI Telecomm. Corp. v. Bell Atl. Pennsylvania, 271

F.3d 491, 506 (3d Cir. 2001). Finally, to the extent that Podems meant to raise any claims

other than those vulnerable to the Defendants’ immunity defenses, the District Court

determined that subject matter jurisdiction over such claims was lacking.

1 The District Court’s choice was consistent with the notion that “we tend to be flexible when applying procedural rules to pro se litigants, especially when interpreting their pleadings.” Mala v. Crown Bay Marina, Inc., 704 F.3d 239, 244 (3d Cir. 2013). 3 Still pro se, Podems timely appealed the District Court’s judgment. We have

jurisdiction under 28 U.S.C. § 1291.

Podems’s central argument in his opening brief is that the Magistrate Judge erred

in denying the two counsel motions.2 The Defendants (now the Appellees) “take no

position on Podems’ entitlement to court-appointed counsel and leave the disposition of

this argument to the discretion of this Court.” Appellees’ Br. 3. Put another way, they

have waived any argument related to the denial-of-counsel issue.

But that is not the only ‘waiver’ with which we are confronted. The Magistrate

Judge’s statutory authority to rule on Podems’s counsel motions derived from 28 U.S.C.

§ 636(b)(1)(A), and we have held that “parties who wish to preserve their objections to a

magistrate’s order entered pursuant to 28 U.S.C. § 636(b)(1)(A) must [first timely] file

their objections in the district court[.]” United Steelworkers of Am., AFL-CIO v. New

Jersey Zinc Co., 828 F.2d 1001, 1007–08 (3d Cir. 1987). The District Court’s local rules

2 Podems has filed a motion seeking both to expand the record on appeal, and to add a handful of pages of argument to his opening brief. See Doc. 15. That motion is granted in part, and denied in part. The motion is granted as to argument-expansion, and we have considered those additional pages as if they were included in the opening brief. Nowhere in the additional pages, however, does Podems present a viable basis to disturb the judgment below. As for record-expansion, because we may take judicial notice of court decisions, like the ones cited at the beginning of this opinion, see Orabi v. Att’y Gen., 738 F.3d 535, 537 n.1 (3d Cir. 2014); In re Indian Palms Assocs., Ltd., 61 F.3d 197, 205– 06 (3d Cir. 1995), Podems’s motion is, in part, unnecessary. In any event, Podems’s motion, insofar as it seeks to expand the record, is denied because he does not satisfy the standard under Federal Rule of Appellate Procedure 10(e). For that same reason, Podems’s second motion to expand the record, see Doc. 27, is also denied. 4 provide that an appeal of a Magistrate Judge’s ruling on a non-dispositive pretrial motion

must (in the absence of a timely motion for re-argument) be “filed within 14 days after

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Andrew Podems v. Union County Child Support Enforcement Unit, Counsel Stack Legal Research, https://law.counselstack.com/opinion/andrew-podems-v-union-county-child-support-enforcement-unit-ca3-2025.