Harmon v. Goodwin

District Court, W.D. Kentucky·Decided August 7, 2025·No. 3:24-cv-00047·Unknown

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION CIVIL ACTION NO. 3:24-CV-00047-GNS

TERESA HARMON PLAINTIFF

v.

HON. LORI GOODWIN et al. DEFENDANTS

MEMORANDUM OPINION AND ORDER This matter is before the Court on Defendants’ Motions to Dismiss (DN 74, 97) and Plaintiff’s Motions for Leave to File Excess Pages (DN 101, 106). The motions are ripe for adjudication. I. BACKGROUND This matter relates to two family court cases filed in Jefferson Family Court (Kentucky). (1st Am. Compl. ¶ 2, DN 6). Plaintiff Teresa Harmon (“Harmon”) claims she and her two children, I.H. and S.H. (collectively, “Plaintiffs”), had their constitutional rights violated, and were subjected to tortious conduct during a series of child custody hearings and actions. (1st Am. Compl. ¶¶ 3-5, 25-55). Plaintiffs filed this action asserting various federal and state law claims against numerous defendants. (1st Am. Compl. ¶¶ 54-322). For purposes of the pending motion, individual Defendants against whom Plaintiffs have asserted claims in both individual and official capacities are James K. Murphy (“Murphy”) and Abigail Green (“Green”). (1st Am. Compl. ¶¶ 11, 12). Plaintiffs allege that Murphy is an attorney who was appointed as friend of the court (“FOC”) in one of the family court cases, and Green is an attorney who was appointed guardian ad litem (“GAL”) in both family court cases.1 (1st Am. Compl. ¶¶ 11, 12). Murphy and Green have moved to dismiss all claims asserted against them pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6). (Def.’s Mot. Dismiss, DN 74 [hereinafter Murphy’s Mot. Dismiss]; Def.’s Mot. Dismiss, DN 97 [hereinafter Green’s Mot. Dismiss]. Harmon opposes the

motions. (Pl.’s Resp. Def.’s Mot. Dismiss, DN 101-1; Pl.’s Resp. Def.’s Mot. Dismiss, DN 106- 1). Harmon has moved for leave to file responses to Murphy and Green’s motions in excess of the page limitation imposed by LR 7.1(d). (Pl.’s Mot. Leave File Excessive Pages, DN 101; Pl.’s Mot. Leave File Excessive Pages, DN 106). No response was filed to Harmon’s motions, which are therefore granted. II. DISCUSSION2 Generally, threshold challenges to subject matter jurisdiction under Fed. R. Civ. P. 12(b)(1) should be decided before any ruling on the merits under Fed. R. Civ. P. 12(b)(6). See

1 The 1st Amended Complaint purports to assert claims against Murphy and Green by Harmon on behalf of I.H. and S.H. The Sixth Circuit has held that “parents cannot appear pro se on behalf of their minor children because a minor’s personal cause of action is her own and does not belong to her parent or representative.” Shepherd v. Wellman, 313 F.3d 963, 970 (6th Cir. 2002) (citing Cheung v. Youth Orchestra Found. of Buffalo, Inc., 906 F.2d 59, 61 (2d Cir.1990); see also Watkins v. Kentucky, No. 1:23-CV-00088-RGJ, 2023 WL 7093042, at *2 (W.D. Ky. Oct. 25, 2023) (“Under 28 U.S.C. § 1654, ‘[i]n all courts of the United States the parties may plead and conduct their own cases personally or by counsel[.]’ That statute, however, ‘does not permit plaintiffs to appear pro se where interests other than their own are at stake.’” (quoting Shepherd, 313 F.3d at 963)). Therefore, because Harmon cannot proceed pro se on behalf of I.H. and S.H., the claims asserted on behalf of I.H. and S.H. are dismissed without prejudice. 2 The 1st Amended Complaint purports to assert claims against Murphy and Green in their individual and official capacities. (1st Am. Compl. ¶¶ 11-12). As this Court has recognized, a private party cannot be sued in his or her official capacity. See Valdes v. Evans, No. 5:19CV-P4- TBR, 2019 WL 334171, at *3 (W.D. Ky. Jan. 25, 2019) (citing Lester v. Extendicare, Inc., No. 6:13-CV-21, 2013 WL 3781300 at *3 (E.D. Ky. July 18, 2013)). Therefore, because Murphy and Green are private parties, Harmon has not stated an official capacity claim against them, and any such claims are dismissed. Bell v. Hood, 327 U.S. 678, 682 (1946). In most circumstances, a plaintiff bears the burden to survive Fed. R. Civ. P. 12(b)(1) motions to dismiss for lack of subject matter jurisdiction. See id. Challenges to subject matter jurisdiction come in several varieties. Facial attacks challenge a plaintiff’s establishment of jurisdiction in the complaint and require a court to examine the jurisdictional basis. See United States v. Ritchie, 15 F.3d 592, 598 (6th Cir. 1994)

(citation omitted). Factual attacks contest the existence of factual prerequisites to jurisdiction. See id. In such motions, in contrast to motions under Fed. R. Civ. P. 12(b)(6), a court is empowered to resolve the factual disputes affecting any jurisdictional prerequisites. See Rogers v. Stratton Indus., Inc., 798 F.2d 913, 915 (6th Cir. 1986). A plaintiff bears the burden in both these situations. See Bell, 327 U.S. at 682. When considering a Rule 12(b)(6) motion, a court “must construe the complaint in the light most favorable to [the plaintiff] . . . .” League of United Latin Am. Citizens v. Bredesen, 500 F.3d 523, 527 (6th Cir. 2007) (citation omitted). A court must also accept all of the plaintiff’s allegations as true. See Ashcroft v. Iqbal, 556 U.S. 662, 679 (2009). Mere “labels and

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