Belinda Robertson v. Michelle Lujan Grisham and Manuel Arrieta

District Court, D. New Mexico·Decided September 9, 2026·No. 2:26-cv-02673·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO BELINDA ROBERTSON, Plaintiff, v. No. 2:26-cv-02673-SMD-GJF

MICHELLE LUJAN GRISHAM and MANUEL ARRIETA, Defendants. MEMORANDUM OPINION AND ORDER OF DISMISSAL This case arises from a divorce proceeding in state court in which pro se Plaintiff is a party. See Civil Rights Complaint Pursuant to 42 U.S.C. § 1983 at 7, Doc. 1, filed August 13, 2026 (“Complaint”). In her case in this Court, Plaintiff asserted speedy trial and due process claims pursuant to 42 U.S.C. § 1983, claims pursuant to 18 U.S.C. § 242 and claims pursuant to state law against State of New Mexico Governor Michelle Lujan Grisham and New Mexio state-court Judge Manuel Arrieta. See Complaint at 7-13. Plaintiff alleged Judge Arrieta violated Plaintiff’s constitutional rights during state-court proceedings by making rulings outside his official capacity: Plaintiff Alleges New Mexico Court Officials violated her Constitutional Rights during a Divorce proceeding and seeks redress under 42 U.S.C & 1983. . . “Plaintiff was affected for Government officer not in his official capacity in review the case for more than 4 years in a District Court . . . Defendant (Judge not in his official Capacity) by her ex parte and Sua sponte rulings to violate the Plaintiff’s” due Process Rights”.

[sic] Complaint at 8. Plaintiff alleged Governor Lujan Grisham appointed Judge Arrieta to the case while “not in her official capacity.” Complaint at 3. Plaintiff did not seek monetary relief. See Complaint at 14 (stating in her prayer for relief “No Monetary Relief”). Plaintiff is proceeding in forma pauperis pursuant to 28 U.S.C. § 1915. See Order Granting Application to Proceed In Forma Pauperis, Doc. 4, filed August 28, 2026. United States Magistrate Judge Gregory J. Fouratt notified Plaintiff of several deficiencies in the Complaint and ordered Plaintiff to show cause why the Court should not dismiss this case and to file an amended complaint. See Order to Show Cause, Doc. 4, filed August 28, 2026.

Plaintiff filed a response to the Order to Show Cause and an Amended Complaint combined in one document. See Amedment Complain Show Cause [sic] at 1, Doc. 5, filed September 3, 2026 (stating Plaintiff “brings a Complain under Pursuant 42 U.S.C. & 1983” [sic]) (“Amended Complaint”). The Amended Complaint fails to remedy the deficiencies identified by Judge Fouratt. First, Judge Fouratt notified Plaintiff that it appears Plaintiff may be seeking injunctive relief against the state-court proceedings and that Plaintiff has not shown that this Court has authority to enjoin the state-court case explaining that: The Anti–Injunction Act ordinarily precludes injunctions against state-court proceedings. 28 U.S.C. § 2283. But three exceptions exist:

1. Congress “expressly authorized” an injunction.

2. The injunction is “necessary in aid of [the federal district court's] jurisdiction.”

3. The injunction is necessary to “protect or effectuate” a previous judgment in federal district court.

The Anti–Injunction Act's exceptions are narrow and are not to be loosely construed. Smith v. Bayer Corp., 564 U.S. 299, 131 S.Ct. 2368, 2375, 180 L.Ed.2d 341 (2011). As a result, courts should resolve doubts about the applicability of an exception in favor of allowing the state-court proceeding to continue. Id., 131 S.Ct. at 2382. Tooele County v. United States, 820 F.3d 1183, 1187-88 (10th Cir. 2016). Plaintiff has not shown that any of the three exceptions to the Anti-Injunction Act apply in this case.

Order to Show Cause at 3-4. The Amended Complaint fails to show that this Court can enjoin the proceedings in state court. Plaintiff asserts the injunction is necessary in aid of this Court’s jurisdiction because Judge Arrieta was not acting in his official capacity, the state-court case is not a civil case but instead is a criminal case, and the state-court case is not appealable. See Amended Complaint at 4-6, 19. “‘Necessary in aid of its jurisdiction’ means that ‘federal injunctive relief may be necessary to prevent a state court from so interfering with a federal court's consideration or disposition of a case as to seriously impair the federal court's flexibility and authority to decide that case.’” Zurich American Ins. Co. v. Superior Court for State of California 326 F.3d 816, 825 (7th Cir. 2002) (quoting Atlantic Coast Line R.R. Co. v. Broth. Of Locomotive Eng’rs., 398 U.S. 281 295 (1970)); Texas v. United States, 837 F.2d 184, 186 n.4 (5th Cir. 1988) (“In no event may the ‘aid of jurisdiction’ exception be invoked merely because of the prospect that a concurrent state proceeding might result in a judgment inconsistent with the federal court's decision”) (citing Atlantic Coast Line R. Co. v. Brotherhood of Locomotive Engineers, 398 U.S. 281, 295–96 (1970)). Plaintiff also asserts this Court has the authority to enjoin the state-court proceedings pursuant to the All Writs Act, 28 U.S.C. 1651. See Amended Complaint at 6. The All Writs Act states: “The Supreme Court and all courts established by act of Congress may issue all writs necessary or appropriate in aid of their respective jurisdictions and agreeable to the usages and principles of law.” 28 U.S.C. 1651(a). The Amended Complaint does not contain allegations showing that the state-court proceeding will impair this Court’s ability to decide this case or otherwise show that this Court has authority to enjoin the state-court proceedings. Second, Judge Fouratt notified Plaintiff it appears Plaintiff may also be seeking to remove the state-court case to this Court. See Order to Show Cause at 4. Judge Fouratt explained that Plaintiff has not shown that the state-court case can be removed to this Court because: (i) Plaintiff is the plaintiff in the state-court case; (ii) “[P]laintiffs are not entitled to remove cases to federal court;” and (iii) Plaintiff has not cited any legal authority which would allow her, as plaintiff in the

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Belinda Robertson v. Michelle Lujan Grisham and Manuel Arrieta, (D.N.M. 2026).

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