Hill v. Trumbull County Child Support Enforcement Agency

CourtDistrict Court, N.D. Ohio
DecidedAugust 6, 2025
Docket4:25-cv-00709
StatusUnknown

This text of Hill v. Trumbull County Child Support Enforcement Agency (Hill v. Trumbull County Child Support Enforcement Agency) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hill v. Trumbull County Child Support Enforcement Agency, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

PAUL HENRY MANDAIL HILL, ) CASE NO. 4:25-cv-709 ) ) PLAINTIFF, ) CHIEF JUDGE SARA LIOI ) ) ) vs. ) MEMORANDUM OPINION ) AND ORDER TRUMBULL COUNTY CHILD SUPPORT ) EMFORCEMENT AGENCY, et al., ) ) ) DEFENDANTS. )

Pro se plaintiff Paul Henry Mandail Hill filed this civil rights action pursuant to 42 U.S.C. § 1983 against Trumbull County Child Support Enforcement Agency (“CSEA”), Trumbull County Commissioners, CSEA employees Robert March and Carmel Schehi, and Title IV-D “Obligee” Sarah Monroe (collectively “defendants”) alleging that defendants violated his constitutional rights in connection with a state child support order issued against him. (See generally Doc. No. 3 (First Amended Complaint, hereinafter “complaint”).) Plaintiff filed a motion to proceed in forma pauperis (Doc. No. 2), which the Court grants. For the reasons set forth below, this case is dismissed. I. BACKGROUND Plaintiff’s complaint is difficult to discern and contains few factual allegations. Plaintiff, who represents that he is a “private American citizen and Authorized Representative of the Paul H. Hill Living Trust” (Doc. No. 3 ¶ 3), maintains that he “was subjected to administrative enforcement based on an alleged child support order” that was “issued without proper due process, notice, or opportunity to be heard.” (Id. ¶¶ 8–9.) He further alleges that a “default judgment was entered unlawfully, without lawful service or jurisdiction.” (Id. ¶ 10.) Additionally, he contends that the “child support enforcement was executed in violation of [his] constitutional rights and Title IV-D procedures[,]” and that “[a]ll funds seized under the order constitute unlawful conversion of trust assets and unjust enrichment by” defendants. (Id. ¶¶ 11–12.) He seeks compensatory damages, restitution “of all funds unlawfully taken from the Paul H. Hill Living Trust[,]” interest, an order declaring the child support order “void ab initio,” and an injunction against “further enforcement” of the child support order. (Id. at 31 (Prayer for Relief).) Plaintiff filed a “Notice” requesting that the Court “amend the docket caption” to show that the plaintiff in the case is the “Paul H. Hill Living Trust” (Doc. No. 11), two motions for default

judgment(Doc. No. 12, 14), and a motion to compel judicial determination and trust payment (Doc. No. 15.) These motions are denied,2 and, for the reasons that follow, the Court finds that plaintiff’s complaint warrants sua sponte dismissal. II. STANDARD OF REVIEW AND DISCUSSION A federal district court is expressly required, under 28 U.S.C. § 1915(e)(2)(B), to review all in forma pauperis complaints filed in federal court and to dismiss any such action that the court determines is frivolous or malicious, fails to state a claim upon which relief may be granted, or seeks monetary relief from a defendant who is immune from such relief. To survive a dismissal

1 All page number references herein are to the consecutive page numbers applied to each individual document by the Court’s electronic filing system. 2 As a pro se litigant, plaintiff may not represent the interests of another litigant in federal court, and trusts must be represented by a licensed attorney. See Williams Huron Gardens 397 Trust v. Township of Waterford, No. 18-12319, 2019 WL 2051967, at *3 (E.D. Mich. Feb. 28, 2019). Default judgment is not warranted, and although plaintiff contends he has served defendants, no valid proof of service is reflected on the Court’s docket. Plaintiff’s motion to compel a judicial determination (Doc. No. 15) is denied as moot. 2 for failure to state a claim, a complaint must set forth sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face. Hill v. Lappin, 630 F.3d 468, 471 (6th Cir. 2010) (holding that the dismissal standard articulated in Ashcroft v. Iqbal, 556 U.S. 662, 678, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009) and Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 555–57, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007) governs dismissals under 28 U.S.C. § 1915(e)(2)(B)). In addition, federal courts are courts of limited jurisdiction and have a duty to police the boundaries of their jurisdiction in every case. See Fed. R. Civ. P. 12(h)(3). A “district court may, at any time, sua sponte dismiss a complaint for lack of subject matter jurisdiction pursuant to Rule 12(b)(1) of the Federal Rules of Civil Procedure when the allegations of [the] complaint are totally implausible, attenuated, unsubstantial, frivolous, devoid of merit, or no longer open to discussion."

Apple v. Glenn, 183 F.3d 477, 479 (6th Cir. 1999) (citations omitted) Here, the Court’s subject matter jurisdiction is limited by the Rooker-Feldman doctrine,3 which provides that “federal district courts generally lack jurisdiction to review and determine the validity of state court judgments, even in the face of allegations that the state court’s action was unconstitutional.” Carr v. Spencer, 13 F. App’x 296, 298 (6th Cir. 2001) (cleaned up). Put differently, Rooker-Feldman prevents a party from taking “an appeal of an unfavorable state-court decision to a lower federal court.” Lance v. Dennis, 546 U.S. 459, 466, 126 S. Ct. 1198, 163 L. Ed. 2d 1059 (2006). Only the United States Supreme Court is empowered to review state court judgments, Carr, 13 F. App’x at 298, and even then, only if they come from “the highest court of

a State[.]” 28 U.S.C. § 1257.

3 The Rooker-Feldman doctrine is derived from two Supreme Court cases: Rooker v. Fidelity Tr. Co., 263 U.S. 413, 44 S. Ct. 149, 68 L. Ed. 362 (1923) and Dist. of Columbia Ct. of Appeals v. Feldman, 460 U.S. 462, 103 S. Ct. 1303, 75 L. Ed. 2d 206 (1983). 3 The doctrine applies to cases that are “[1] brought by state-court losers [2] complaining of injuries caused by state-court judgments [3] rendered before the district court proceedings commenced and [4] inviting district court review and rejection of those judgments.” Adams v. Calhoun Cnty., No. 18-1867, 2019 WL 3501815, at *2–3 (6th Cir. Apr. 24, 2019) (quoting Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284, 125 S. Ct. 1517, 161 L. Ed. 2d 454 (2005)). The pertinent inquiry is whether the “source of the injury” upon which plaintiff bases his federal claim is a state court judgment. Id. (citing Kovacic v. Cuyahoga Cnty. Dep't of Children & Family Servs., 606 F.3d 301, 309 (6th Cir. 2010)).

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Related

Rooker v. Fidelity Trust Co.
263 U.S. 413 (Supreme Court, 1924)
District of Columbia Court of Appeals v. Feldman
460 U.S. 462 (Supreme Court, 1983)
Exxon Mobil Corp. v. Saudi Basic Industries Corp.
544 U.S. 280 (Supreme Court, 2005)
Lance v. Dennis
546 U.S. 459 (Supreme Court, 2006)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Hill v. Lappin
630 F.3d 468 (Sixth Circuit, 2010)
Thomas L. Apple v. John Glenn, U.S. Senator
183 F.3d 477 (Sixth Circuit, 1999)
Harrington v. Grayson
811 F. Supp. 1221 (E.D. Michigan, 1993)
Catz v. Chalker
142 F.3d 279 (Sixth Circuit, 1998)
Carr v. Spencer
13 F. App'x 296 (Sixth Circuit, 2001)
Frazier v. State of Michigan
41 F. App'x 762 (Sixth Circuit, 2002)
Gilmore v. Corrections Corp.
92 F. App'x 188 (Sixth Circuit, 2004)

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Hill v. Trumbull County Child Support Enforcement Agency, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hill-v-trumbull-county-child-support-enforcement-agency-ohnd-2025.