Holt v. Cuyahoga County Court of Common Pleas

CourtDistrict Court, N.D. Ohio
DecidedAugust 20, 2025
Docket1:25-cv-01706
StatusUnknown

This text of Holt v. Cuyahoga County Court of Common Pleas (Holt v. Cuyahoga County Court of Common Pleas) 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
Holt v. Cuyahoga County Court of Common Pleas, (N.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION Heaven-Marshay Holt, ) CASE NO. 1:25 CV 1706 ) Plaintiff, ) JUDGE PATRICIA A. GAUGHAN ) v. ) ) Cuyahoga County Court ) of Common Pleas, et al., ) Memorandum of Opinion ) and Order Defendants. ) Pro se Plaintiff Heaven-Marshay Holt filed this civil rights action under 42 U.S.C. § 1983 against the Cuyahoga County Court of Common Pleas; Magistrate Elizabeth Howe; Judge Nicholas J. Celebrezze; “Clerk of Court”; Cynthia A. Ernst, Guardian Ad Litem; Isaiah Miles Nash; the Bedford Police Department; the Cuyahoga County Children and Family Services; and the Ohio Division of Child and Family Services. (Doc. No. 1). The complaint concerns the custody of Plaintiff’s minor child. Plaintiff also filed an emergency motion for temporary restraining order and motion for preliminary injunction. (Doc. No. 3). Additionally, Plaintiff filed an application to proceed in forma pauperis (Doc. No. 2), which the Court grants. I. BACKGROUND Plaintiff’s complaint contains very few factual allegations. But it appears that the Cuyahoga County Court of Common Pleas, Juvenile Division, awarded custody of Plaintiff’s minor child to the child’s father on June 16, 2025. (See Doc. Nos. 3-8, 3-8). According to exhibits attached to the complaint, Plaintiff failed to comply with the Juvenile Court order and repeatedly refused to relinquish custody of the child. (Id.). Ultimately, the child was removed from Plaintiff’s home. (See Doc. No. 3). Thereafter, Plaintiff was arrested and charged with custodial interference. See State of Ohio v. Holt, No. 25CRB01122 (Bedford Mun. Ct. Aug. 13,

2025). That case remains pending. (Id.). Plaintiff appears to be challenging the state court’s custody order. She also objects to actions taken by the Bedford Police Department that resulted in the ultimate removal of Plaintiff’s child from her custody and Plaintiff’s arrest. She claims in a conclusory fashion an unlawful denial of her rights. (See Doc. No. 1 at 6). In support, Plaintiff lists various federal laws that Defendants have purportedly violated, including 42 U.S.C. §§ 1983 and 1985, the Fourth, Fifth, and Fourteenth Amendments, and 18 U.S.C. §§ 241 and 242. (Doc. No. 1 at 4). Plaintiff seeks the following relief: the immediate return of Plaintiff’s minor child to her

custody; an order prohibiting the defendants from “removing, detaining, or otherwise interfering with” Plaintiff’s custody; an immediate suspension of all state and local court proceedings and orders concerning the child’s custody; an order to preserve all evidence concerning the custody proceedings; federal enforcement of “Plaintiff’s lawful custodial authority”; and monetary damages. (Doc. No. 1 at 8). II. STANDARD OF REVIEW Pro se pleadings are liberally construed. Boag v. MacDougall, 454 U.S. 364, 365, 102 S.

Ct. 700, 70 L. Ed. 2d 551 (1982) (per curiam); Haines v. Kerner, 404 U.S. 519, 520, 92 S. Ct. 594, 30 L. Ed. 2d 652 (1972). The court, however, is required to dismiss an in forma pauperis action under 28 U.S.C. §1915(e) if it fails to state a claim upon which relief can be granted, or if -2- it lacks an arguable basis in law or fact. Neitzke v. Williams, 490 U.S. 319, 109 S. Ct. 1827, 104 L. Ed. 2d 338 (1989); Lawler v. Marshall, 898 F.2d 1196 (6th Cir. 1990); Sistrunk v. City of Strongsville, 99 F.3d 194, 197 (6th Cir. 1996). A claim lacks an arguable basis in law or fact when it is premised on an indisputably meritless legal theory or when the factual contentions are

clearly baseless. Neitzke, 490 U.S. at 327. A cause of action fails to state a claim upon which relief may be granted when it lacks “plausibility in the Complaint.” Bell Atl. Corp. v. Twombly, 550 U.S. 544, 564, 127 S. Ct. 1955, 167 L. Ed. 2d 929 (2007). A pleading must contain a “short and plain statement of the claim showing that the pleader is entitled to relief.” Ashcroft v. Iqbal, 556 U.S. 662, 677-78, 129 S. Ct. 1937, 173 L. Ed. 2d 868 (2009). The factual allegations in the pleading must be sufficient to raise the right to relief above the speculative level on the assumption that all the allegations in the complaint are true. Twombly, 550 U.S. at 555. The plaintiff is not required to include

detailed factual allegations but must provide more than “an unadorned, the Defendant unlawfully harmed me accusation.” Iqbal, 556 U.S. at 678. A pleading that offers legal conclusions or a simple recitation of the elements of a cause of action will not meet this pleading standard. Id. In reviewing a complaint, the court must construe the pleading in the light most favorable to the plaintiff. Bibbo v. Dean Witter Reynolds, Inc., 151 F.3d 559, 561 (6th Cir.1998). III. DISCUSSION

A. Child Custody To the extent Plaintiff is challenging the state court’s child custody determination and asking this Court to vacate the state court judgment concerning her custodial rights and enter -3- judgment in her favor, the Rooker-Feldman doctrine bars this Court’s consideration of her claims. Under the Rooker-Feldman doctrine, a party losing his or her case in state court is barred from seeking what in substance would be appellate review of the state judgment in a United

States district court based on the party’s claim that the state judgment itself violates his or her federal rights. Berry v. Schmitt, 688 F.3d 290, 298-99 (6th Cir. 2012). Federal appellate review of state court judgments can only occur in the United States Supreme Court. See Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 483, 103 S. Ct. 1303, 75 L. Ed. 2d 206 (1983); Rooker v. Fidelity Trust Co., 263 U.S. 413, 415-16, 44 S. Ct. 149, 68 L. Ed. 362 (1923). The Rooker-Feldman doctrine applies only where a party losing his or her case in state court initiates an action in federal district court complaining of injury caused by a state court judgment itself and seeks review and rejection of that judgment. Berry, 688 F.3d 298-99; In re

Cook, 551 F.3d 542, 548 (6th Cir. 2009). To determine whether Rooker-Feldman bars a claim, the court must look to the “source of the injury the plaintiff alleges in the federal complaint.” McCormick v. Braverman, 451 F.3d 382, 393 (6th Cir.2006); see Berry, 688 F.3d at 299. If the source of the plaintiff’s injury is the state court judgment itself, then the Rooker-Feldman doctrine bars the federal claim. McCormick, 451 F.3d at 393. “If there is some other source of injury, such as a third party’s actions, then the plaintiff asserts an independent claim.” Id.; see Lawrence v. Welch, 531 F.3d 364, 368-69 (6th Cir. 2008). In conducting this inquiry, the court

also considers the plaintiff’s requested relief. Evans v. Cordray, 424 Fed. App’x. 537, 2011 WL 2149547, at *1 (6th Cir. 2011).

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Rooker v. Fidelity Trust Co.
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Allen v. McCurry
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Boag v. MacDougall
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Lugar v. Edmondson Oil Co.
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District of Columbia Court of Appeals v. Feldman
460 U.S. 462 (Supreme Court, 1983)
Diamond v. Charles
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Pennzoil Co. v. Texaco Inc.
481 U.S. 1 (Supreme Court, 1987)
West v. Atkins
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Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
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Nathaniel Denman v. James K. Leedy
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