Jaron Blue Butler v. Travis John Willey, et al.

District Court, D. Maine·Decided April 17, 2026·No. 1:26-cv-00119·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MAINE JARON BLUE BUTLER, ) ) Plaintiff ) ) v. ) 1:26-cv-00119-LEW ) TRAVIS JOHN WILLEY, et al., ) ) Defendants ) RECOMMENDED DECISION AFTER REVIEW OF PLAINTIFF’S SECOND AMENDED COMPLAINT Plaintiff, who is in custody at the Maine State Prison, seeks to assert a federal claim based upon constitutional violations that the defendants, who are employees of the Maine Department of Health and Human Services, allegedly committed in the context of state child protection proceedings. (Second Amended Complaint, ECF Nos. 11, 13.)1 Plaintiff filed an application to proceed without prepayment of fees (ECF No. 4), which application the Court granted. (Order, ECF No. 5.) In accordance with the statute that governs actions where a plaintiff proceeds without prepayment of fees, a preliminary review of Plaintiff’s second amended complaint is appropriate. 28 U.S.C. § 1915(e)(2). Additionally, Plaintiff’s second amended complaint is subject to screening “before docketing, if feasible or … as soon as practicable after docketing,”

1On consecutive days, Plaintiff filed two amended complaints. I considered both filings collectively as Plaintiff’s second amended complaint. because he is “a prisoner seek[ing] redress from a governmental entity or officer or employee of a governmental entity.” 28 U.S.C. § 1915A(a). After a review of Plaintiff’s second amended complaint, I recommend the Court dismiss

the matter. LEGAL STANDARD 28 U.S.C. § 1915 is designed to ensure meaningful access to the federal courts for individuals unable to pay the cost of bringing an action. When a party is proceeding pursuant to § 1915, however, “the court shall dismiss the case at any time if the court determines,” inter alia, that the action is “frivolous or malicious” or “fails to state a claim on which relief may be granted.” 28 U.S.C. § 1915(e)(2)(B). “Dismissals [under § 1915] are often made sua sponte

prior to the issuance of process, so as to spare prospective defendants the inconvenience and expense of answering such complaints.” Neitzke v. Williams, 490 U.S. 319, 324 (1989). The § 1915A screening requires courts to “identify cognizable claims or dismiss the complaint, or any portion of the complaint, if the complaint (1) is frivolous, malicious, or fails to state a claim …; or (2) seeks monetary relief from a defendant who is immune from such relief.” 28 U.S.C. § 1915A(b). When considering whether a complaint states a claim for which relief may be granted,

courts must assume the truth of all well-plead facts and give the plaintiff the benefit of all reasonable inferences therefrom. Ocasio-Hernandez v. Fortuno-Burset, 640 F.3d 1, 12 (1st Cir. 2011). A complaint fails to state a claim upon which relief can be granted if it does not plead “enough facts to state a claim to relief that is plausible on its face.” Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570 (2007). “A self-represented plaintiff is not exempt from this framework, but the court must construe his complaint ‘liberally’ and hold it ‘to less stringent standards than formal pleadings drafted by lawyers.’” Waterman v. White Interior Sols., No. 2:19-cv-00032-JDL, 2019 WL 5764661, at *2 (D. Me. Nov. 5, 2019) (quoting Erickson v. Pardus, 551 U.S. 89, 94 (2007)). “This is not to say that pro se plaintiffs are not required to

plead basic facts sufficient to state a claim.” Ferranti v. Moran, 618 F.2d 888, 890 (1st Cir. 1980). DISCUSSION Plaintiff alleges that the defendants unlawfully seized his children and, through exaggerated allegations and false statements, sought and obtained a court order terminating his parental rights. “The Rooker-Feldman doctrine prevents the lower federal courts from exercising

jurisdiction over cases brought by ‘state-court losers’ challenging ‘state-court judgments rendered before the district court proceedings commenced.’” Lance v. Dennis, 546 U.S. 459, 460 (2006) (quoting Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005), and discussing Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) and District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983)). In general, “the proper

forum for challenging an unlawful state court ruling” is the state appellate system followed by a petition for review by the United States Supreme Court. Davison v. Gov’t of Puerto Rico-Puerto Rico Firefighters Corps., 471 F.3d 220, 223 (1st Cir. 2006); 28 U.S.C. § 1257. This Court previously observed that “multiple federal courts have acknowledged that federal cases seeking to challenge the termination of parental rights by state courts fall

within the heartland of cases preempted by the Rooker–Feldman doctrine.” Miller v. Nichols, 592 F. Supp. 2d 191, 195-96 (D. Me. 2009) (citing Hoblock v. Albany County Bd. of Elections, 422 F.3d 77, 87 (2d Cir.2005) (“Suppose a state court . . . terminates a father’s parental rights and orders the state to take custody of his son. If the father sues in federal

court for the return of his son on grounds that the state judgment violates his federal substantive due-process rights as a parent, he is complaining of an injury caused by the state judgment and seeking its reversal. This he may not do, regardless of whether he raised any constitutional claims in state court, because only the Supreme Court may hear appeals from state-court judgments.”); Doe v. Mann, 415 F.3d 1038, 1043 (9th Cir. 2005) (concluding that a challenge to the termination of parental rights fell “within the traditional

boundaries of the Rooker–Feldman doctrine” while ultimately holding that there was jurisdiction based on a narrow exception for “child custody proceedings involving Indian children”). Through this action, Plaintiff challenges the state court proceeding that resulted in the termination of his parental rights. In other words, Plaintiff seeks relief from the state court’s

order terminating his parental rights. As with the claim asserted in Miller, Plaintiff’s claim is precluded by the Rooker-Feldman doctrine. Dismissal, therefore, is warranted. Even if Plaintiff’s claim was not barred by the Rooker-Feldman doctrine, dismissal is appropriate because Plaintiff’s second amended complaint lacks sufficient facts to support an actionable claim.

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Jaron Blue Butler v. Travis John Willey, et al., (D. Me. 2026).

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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)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
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)
Erickson v. Pardus
551 U.S. 89 (Supreme Court, 2007)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Ocasio-Hernandez v. Fortuno-Burset
640 F.3d 1 (First Circuit, 2011)
David R. Ferranti v. John J. Moran
618 F.2d 888 (First Circuit, 1980)
Doe v. Mann
415 F.3d 1038 (Ninth Circuit, 2005)
Young v. Wells Fargo Bank, N.A.
717 F.3d 224 (First Circuit, 2013)
Miller v. Nichols
592 F. Supp. 2d 191 (D. Maine, 2009)