King v. Florida Department of Children and Families

CourtDistrict Court, W.D. Texas
DecidedNovember 21, 2024
Docket5:24-cv-01243
StatusUnknown

This text of King v. Florida Department of Children and Families (King v. Florida Department of Children and Families) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
King v. Florida Department of Children and Families, (W.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

BRITTNEY KING, AS MOTHER AND § NATURAL GUARDIAN OF J.S. AND § A.S.; § SA-24-CV-01243-XR § Plaintiff, § § vs. § § FLORIDA DEPARTMENT OF § CHILDREN AND FAMILIES, ONE § HOPE UNITED, FLORIDA 9TH § CIRCUIT COURT, LISA SMITH § BEDWELL,

Defendants.

REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE

To the Honorable United States District Judge Xavier Rodriguez: This Report and Recommendation concerns Plaintiff’s pro se Application to Proceed in District Court without Prepaying Fees or Costs and proposed civil complaint [#1]. This case was automatically referred to the undersigned upon filing, and the undersigned has authority to enter this report and recommendation pursuant to 28 U.S.C. § 636(b)(1)(B). By his motion, Plaintiff seeks leave to proceed in forma pauperis (“IFP”) based on her inability to afford court fees and costs. Having considered the motion and documentation provided by Plaintiff, the undersigned recommends the Court grant the motion but recommend the District Court dismiss this case for lack of subject matter jurisdiction. I. Motion to Proceed IFP All parties instituting any civil action, suit, or proceeding in a district court of the United States, except an application for a writ of habeas corpus, must pay a filing fee of $350, as well as an administrative fee.1 See 28 U.S.C. § 1914(a). Plaintiff’s motion to proceed IFP includes her income and asset information, which indicates that Plaintiff is unemployed. Plaintiff has no

source of income and no assets except for monthly SNAP food benefits. The Court finds that Plaintiff does not have sufficient monthly resources available to pay the filing fee, and the Court will grant her motion to proceed IFP. II. Review Under Section 1915(e) Pursuant to the Court’s October 8, 2019 Standing Order, the undersigned has also reviewed Plaintiff’s proposed Complaint under the standards set forth in Section 1915(e). For the reasons that follow, the undersigned recommends that the District Court dismiss all of Plaintiff’s claims. Pursuant to 28 U.S.C. § 1915(e), the Court is empowered to screen any civil complaint

filed by a party proceeding IFP to determine whether the claims presented are (1) frivolous or malicious; (2) fail to state a claim on which relief may be granted; or (3) seek monetary relief against a defendant who is immune from such relief. See 28 U.S.C. § 1915(e)(2)(B). This Court also has an ongoing obligation to evaluate its subject matter jurisdiction. See Gonzalez v. Thaler, 565 U.S. 134, 141 (2012). This case concerns Plaintiff’s custody of two of her children, J.S. and A.S., and her allegation that Defendants committed constitutional and statutory violations in the custody

1 The administrative fee, which is currently $50, is waived for plaintiffs who are granted IFP status. See District Court Miscellaneous Fee Schedule, available at http://www.uscourts.gov/services-forms/fees/district-court-miscellaneous-fee-schedule. proceedings. Plaintiff’s proposed Complaint names four defendants: the Florida Department of Children and Families (“DCF”), One Hope United (which she states is a private child welfare agency contracted by DCF to provide child placement services), the Florida 9th Judicial Circuit Court, and Judge Lisa Smith Bedwell. Plaintiff alleges that her two children were “unlawfully removed from her care” by DCF without a “proper opportunity to be heard in court.” She claims

that Defendants have deprived her of her parental rights without due process in violation of state and federal laws in “ongoing child custody proceedings in Florida.” Specifically, Plaintiff purports to bring claims under the Fourth, Fifth, Sixth, Eight, and Fourteenth Amendments of the U.S. Constitution brought pursuant to 42 U.S.C. § 1983; a due process claim under the Florida Constitution; a claim under Chapter 61 of the Florida Statutes; and two claims under the Texas Family Code. She requests both injunctive and declaratory relief and that this Court “assume jurisdiction over this child custody case.” This case raises numerous concerns regarding jurisdiction, given that Plaintiff’s pleading challenges “ongoing” child custody proceedings in another state. First, this Court cannot

“assume jurisdiction” of the case regarding the custody of Plaintiff’s children. It is well- established that federal courts do not have jurisdiction to decide domestic relations disputes. See Congleton v. Holy Cross Child Placement Agency, Inc., 919 F.2d 1077, 1078 (5th Cir. 1990) (noting that “[a]s a general rule, federal courts refuse to hear ‘suits for . . . child custody . . . .’”); Saloom v. Texas Dep't of Fam. & Child Protective Servs., 578 F. App’x 426, 429–30 (5th Cir. 2014) (stating that the “domestic relations exception” to federal jurisdiction “applies to prevent federal courts from issuing or modifying ‘a divorce, alimony, or child custody decree’”) (citing Ankenbrandt v. Richards, 504 U.S. 689, 701–02 (1992)). Second, to the extent the state court in Florida has made any “final judgment,” the Rooker-Feldman doctrine bars an individual from filing a civil rights suit in federal court to collaterally attack a state civil judgment. See Liedtke v. State Bar of Tex., 18 F.3d 315, 317 (5th Cir. 1994) (citing Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923); Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983)). The Rooker-Feldman doctrine establishes that a

federal court lacks subject matter jurisdiction when issues in federal court are “inextricably intertwined” with a final state court judgment. Davis v. Bayless, 70 F.3d 367, 375 (5th Cir. 1995). Thus, if any final child custody decision has been made, the Plaintiff cannot use this Court to collaterally attack that decision. Third, to the extent the child custody proceedings are “ongoing” (as stated by Plaintiff), this Court should decline to exercise jurisdiction. The Younger abstention doctrine requires that federal courts decline to exercise jurisdiction over lawsuits when three conditions are met: (1) the federal proceeding would interfere with an “ongoing state judicial proceeding”; (2) the state has an important interest in regulating the subject matter of the claim; and (3) the plaintiff has an

adequate opportunity in the state proceedings to raise constitutional challenges. Bice v. La. Pub. Def. Bd., 677 F.3d 712, 716 (5th Cir. 2012) (citing Younger v. Harris, 401 U.S. 37 (1971)). As described above, domestic relations issues, including child custody, are the province of the state; the states therefore have a great interest in regulating child custody matters.

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Related

Davis v. Bayless
70 F.3d 367 (Fifth Circuit, 1995)
Acuna v. Brown & Root Inc.
200 F.3d 335 (Fifth Circuit, 2000)
In Re Burrus
136 U.S. 586 (Supreme Court, 1890)
Rooker v. Fidelity Trust Co.
263 U.S. 413 (Supreme Court, 1924)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
District of Columbia Court of Appeals v. Feldman
460 U.S. 462 (Supreme Court, 1983)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Ankenbrandt Ex Rel. L. R. v. Richards
504 U.S. 689 (Supreme Court, 1992)
J.D. Franks and Margaret Franks v. Van Smith, Etc.
717 F.2d 183 (Fifth Circuit, 1983)
J. Brent Liedtke v. The State Bar of Texas
18 F.3d 315 (Fifth Circuit, 1994)
Bice v. Louisiana Public Defender Board
677 F.3d 712 (Fifth Circuit, 2012)
Shane Gates v. Rodney Strain
885 F.3d 874 (Fifth Circuit, 2018)
Gonzalez v. Thaler
181 L. Ed. 2d 619 (Supreme Court, 2012)
Mitchum v. Foster
407 U.S. 225 (Supreme Court, 1972)

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King v. Florida Department of Children and Families, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-v-florida-department-of-children-and-families-txwd-2024.