Kendrick Simpson v. Christe Quick, et al.

CourtDistrict Court, W.D. Oklahoma
DecidedDecember 19, 2025
Docket5:25-cv-01221
StatusUnknown

This text of Kendrick Simpson v. Christe Quick, et al. (Kendrick Simpson v. Christe Quick, et al.) is published on Counsel Stack Legal Research, covering District Court, W.D. Oklahoma primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kendrick Simpson v. Christe Quick, et al., (W.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF OKLAHOMA

KENDRICK SIMPSON, ) ) Plaintiff, ) ) v. ) Case No. CIV-25-1221-D ) CHRISTE QUICK, et al., ) ) Defendants. )

ORDER

Before the Court is Defendants’ Motion to Dismiss and Brief in Support [Doc. No. 19] (“Motion”). Defendants assert that the Complaint should be dismissed pursuant to both Rules 12(b)(1) and (6) of the Federal Rules of Civil Procedure. Plaintiff filed a Response [Doc. No. 22], to which Defendants replied [Doc. No. 23]. The matter is fully briefed and at issue. BACKGROUND Plaintiff, an Oklahoma death row inmate, was among a group of inmates that challenged Oklahoma’s method-of-execution statute1 in state court. The Oklahoma Court of Criminal Appeals (“OCCA”) denied the claim as unripe. Underwood v. Harpe, PR- 2024-637 (Okla. Crim. App. Sep. 17, 2024). In a later case, the OCCA clarified that its decision was based on the prudential ripeness standard. Littlejohn v. Harpe, PR-2024-740 (Okla. Crim. App. Sep. 25, 2024). Plaintiff filed the Complaint in this lawsuit under 42

1 Okla. Stat. tit. 22, § 1014. U.S.C. § 1983 alleging violations of his constitutional rights to due process, judicial access, and equal protection. Plaintiff names three state officials in their official capacity as Defendants. For relief, he requests this Court “[d]eclare that Oklahoma’s procedural

process violated his rights to due process, judicial access, and equal protection” and “[e]njoin the prison from executing [Plaintiff] until a lawful process is provided in which he can meaningfully challenge the lawfulness of Oklahoma’s execution statute.” Compl. ¶¶ A-B. Defendants allege this Court lacks jurisdiction to hear Plaintiff’s claims, and alternatively, that Plaintiff fails to state a claim upon which relief can be granted.

Manuel Littlejohn (“Littlejohn”), a party to the initial state court lawsuit challenging Oklahoma’s method-of-execution statute, brought a similar federal lawsuit claiming a violation of procedural due process. Littlejohn v. Quick, No. CIV-24-996-SLP, 2024 WL 4314973 (W.D. Okla. Sep. 25, 2024). That suit was dismissed without prejudice for lack of jurisdiction pursuant to the doctrines of both Rooker-Feldman and Eleventh Amendment

immunity. Id. at *2-4. Littlejohn then filed an appeal and emergency motion for a stay of execution pending appeal with the Tenth Circuit. The Tenth Circuit denied the emergency motion for a stay noting that Littlejohn did “not address the jurisdictional basis for the district court’s ruling or establish[] that he is likely to succeed on appeal in arguing that the ruling was incorrect under the Rooker-Feldman doctrine or as to Eleventh Amendment

immunity.” Littlejohn v. Quick, No. 24-6203 (10th Cir. Sep. 26, 2024). STANDARD OF DECISION Under Rule 12(b)(1), a defendant may move the court to dismiss for lack of subject matter jurisdiction. Fed. R. Civ. P. 12(b)(1). It is presumed “that a cause lies outside this [Court’s] limited jurisdiction, and the burden of establishing the contrary rests upon the party asserting jurisdiction.” United States v. Hopson, 150 F.4th 1290, 1298 (10th Cir. 2025). A facial attack regarding subject matter jurisdiction requires the court to accept the

allegations in the complaint as true. Smith v. United States, 561 F.3d 1090, 1097-98 (10th Cir. 2009). DISCUSSION I. Rooker-Feldman The Rooker-Feldman doctrine is a jurisdictional bar “prohibit[ing] federal suits that

amount to appeals of state-court judgments.” Bolden v. City of Topeka, 441 F.3d 1129, 1139 (10th Cir. 2006); Campbell v. City of Spencer, 682 F.3d 1278, 1281 (10th Cir. 2012).2 Rooker-Feldman applies to “cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Exxon Mobil Corp. v.

Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005). Plaintiff claims Rooker-Feldman is not applicable here because 1) his injuries were not caused by the state court’s judgment and 2) he is not asking the Court to review and overturn the state court judgment. Resp. at 16. These defenses are intertwined because courts “approach the question . . . of whether the state-court judgement caused . . . the injury . . . [by] paying close attention to the relief

2 The doctrine is named after the two cases it is derived from. D.C. Ct. of Appeals v. Feldman, 460 U.S. 462 (1983); Rooker v. Fid. Tr. Co., 263 U.S. 412 (1923). sought in the federal suit.” Mo’s Express, LLC v. Sopkin, 441 F.3d 1229, 1237 (citation modified). Plaintiff’s claims require this Court to review the OCCA’s judgment. The type of

appellate review barred by Rooker-Feldman “consists of a review of the proceedings already conducted by the ‘lower’ tribunal to determine whether it reached its result in accordance with law.” Bolden, 441 F.3d at 1143. In contrast, a claim does not run afoul of Rooker-Feldman when the second court can reach a conclusion “without concerning itself with the bona fides of the prior judgment (which may or may not have been a lawful

judgment under the evidence and argument presented to the first court).” Id. Plaintiff does not allege any constitutional violations other than the OCCA’s conclusion that Plaintiff’s claim was not ripe. Providing the relief Plaintiff requests requires wading into the facts and legal analysis performed by the OCCA to determine if the OCCA reached an improper result as to ripeness in Plaintiff’s case based on a faulty application of the law. This is the

type of appellate review barred by Rooker-Feldman. Further, Plaintiff’s requested relief would overturn the OCCA’s judgment. The illustration provided in Bolden is helpful. To illustrate, say a father was deprived of custody of his child by a state-court judgment. If he files suit in federal court, seeking to invalidate the state-court judgment on the ground that the state-court proceedings deprived him of due process or that the judgment was otherwise contrary to federal law, his suit would be barred by Rooker–Feldman; the suit usurps the Supreme Court's exclusive appellate jurisdiction because it seeks to set aside the judgment based on a review of the prior proceedings. If, however, the father simply brought suit in federal court seeking custody of his child, without raising any complaint about the state-court proceedings, Rooker–Feldman cannot be invoked; his federal claim would have been the same even in the absence of the state-court judgment. 441 F.3d at 1145. The only relief this Court could grant would place Plaintiff in the same position he occupied prior to the OCCA’s decisions. This amounts to reversing the OCCA’s judgment. It also demonstrates that the state court judgment is what caused

Plaintiff’s alleged harm; sans allegations regarding the OCCA’s ripeness ruling, Plaintiff’s Complaint is devoid of any specific state action for this Court’s review.

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
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)
Bolden v. City of Topeka
441 F.3d 1129 (Tenth Circuit, 2006)
Mo's Express, LLC v. Sopkin
441 F.3d 1229 (Tenth Circuit, 2006)
Smith v. United States
561 F.3d 1090 (Tenth Circuit, 2009)
Campbell v. City of Spencer
682 F.3d 1278 (Tenth Circuit, 2012)
Skinner v. Switzer
179 L. Ed. 2d 233 (Supreme Court, 2011)
Reed v. Goertz
598 U.S. 230 (Supreme Court, 2023)
Free Speech Coalition v. Anderson
119 F.4th 732 (Tenth Circuit, 2024)
Gutierrez v. Saenz
606 U.S. 305 (Supreme Court, 2025)

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