LEIPHART v. FIRST FAMILIES NETWORK

CourtDistrict Court, N.D. Florida
DecidedMay 12, 2025
Docket3:25-cv-00605
StatusUnknown

This text of LEIPHART v. FIRST FAMILIES NETWORK (LEIPHART v. FIRST FAMILIES NETWORK) is published on Counsel Stack Legal Research, covering District Court, N.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
LEIPHART v. FIRST FAMILIES NETWORK, (N.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF FLORIDA PENSACOLA DIVISION

CHRISTOPHER A. LEIPHART, Individually and as Natural Father and Custodial Guardian of SDJL, a Minor,

Plaintiffs,

v. Case No. 3:25cv605-TKW-HTC

FAMILIES FIRST NETWORK, et al.,

Defendants. ________________________________/ ORDER and REPORT AND RECOMMENDATION

Plaintiff Christopher A. Leiphart, proceeding pro se, has filed an “Emergency Verified Motion for Temporary Preliminary Injunction and Restraining Order” on behalf of him and his minor son.1 Doc. 1. He has also filed a motion to proceed in forma pauperis. Doc. 2. After reviewing the “Emergency Verified Motion,” the

1 The Court notes Leiphart has filed at least six other cases in this Court over the past two weeks related to his ongoing child custody proceedings in state court. See Doc. 1, 3:25v547; Doc. 1, 3:25cv548; Doc. 1, 3:25cv557; Doc. 1, 3:25cv602; Doc. 1, 3:25cv603, Doc. 1; 3:25cv604; Doc. 1. Plaintiff is warned that his ability to file additional cases in this Court may be restricted if he continues his practice of filing multiple lawsuits against anyone and everyone connected to his state child custody proceedings. See Procup v. Strickland, 792 F.2d 1069, 1074 (11th Cir. 1986) (“The court has a responsibility to prevent single litigants from unnecessarily encroaching on the judicial machinery needed by others. [Thus, a plaintiff] can be severely restricted as to what he may file and how he must behave in his applications for judicial relief.”); see also Makere v. Fitzpatrick, No. 4:22cv315/RH/ZCB, 2023 WL 3010539, at *1 (N.D. Fla. Mar. 22, 2023) (imposing filing restrictions against pro se plaintiff). undersigned concludes this case must be DISMISSED because: (1) Leiphart cannot bring claims on behalf of his son; (2) the Court cannot issue injunctive relief in the

absence of a properly-filed complaint; and (3) even with a complaint, Younger v. Harris, 401 U.S. 37 (1971) bars this Court from interfering with ongoing state dependency proceedings. Thus, the motion to proceed in forma pauperis will be

DENIED. I. Background Leiphart identifies the Families First Network and one of its employees, Joe Del Signore, as the Defendants in this case. Leiphart’s “Emergency Verified

Motion” alleges the following. On April 24, 2025, Leiphart’s son was removed from his custody “without judicial warrant, probable cause, or exigent circumstance” in violation of state and

federal law. Leiphart filed a motion earlier in the day “to prevent [the] anticipated unlawful seizure,” but it was “never heard in court.” His son was placed “with a foster party without first establishing necessity, risk, or exploring least restrictive alternatives.” Del Signore has refused to communicate with Leiphart, called him

“sly” and “argumentative,” and ignored a court-appointed therapist’s recommendations. Leiphart contends Defendants are keeping his son in an unlawful placement “based on a dependency petition that post-dated the child’s seizure, with

no legal findings prior to the act.” Based on the foregoing, Leiphart alleges the Defendants violated the Fourth and Fourteenth Amendments by seizing his son “without a warrant or exigency,”

denying him due process before depriving him of custody, and interfering with his parental rights. As relief, he seeks an injunction: (1) preventing Defendants from “continuing to detain or control the placement” of the child; (2) requiring Defendants

“to appear and show cause with competent evidence supporting any lawful basis for removal, including affidavits, orders, or judicial findings”; and (3) requiring Defendants to surrender the minor child to Leiphart “pending lawful proceedings.”2 II. Discussion

A. Leiphart cannot bring claims on behalf of his minor child. Leiphart suggests he is bringing claims on behalf of his son. However, because Leiphart is proceeding pro se, he cannot represent his son’s interests. “The

right to appear pro se … is limited to parties conducting ‘their own cases,’ and does not extend to non-attorney parties representing the interests of others.” FuQua v. Massey, 615 F. App’x 611, 612 (11th Cir. 2015) (finding that “district court properly granted the motion to dismiss because [plaintiff] sought to represent her minor

daughter, but, as a non-attorney, she was not permitted to do so”); see also, L.R. v. Leon Cnty. Sch. Dist., 2019 WL 1177996, at *7 (N.D. Fla. Feb. 14, 2019), report and

2 While the “Emergency Verified Motion” mentions an award of damages, damages cannot be sought through a motion for preliminary injunctive relief. recommendation adopted, 2019 WL 1172012 (N.D. Fla. Mar. 13, 2019) (“a pro se parent does not have the legal right or authority to sue on behalf of a minor child

because a non-attorney cannot act as legal counsel for another person”). As the Eleventh Circuit has recognized, “parents who are not attorneys may not bring a pro se action on their child’s behalf – because it helps to ensure that

children rightfully entitled to legal relief are not deprived of their day in court by unskilled, if caring parents.” Devine v. Indian River Cnty. Sch. Bd., 121 F.3d 576, 582 (11th Cir. 1997), overruled on other grounds by Winkelman v. Parma City Sch. Dist., 550 U.S. 516 (2007)). Thus, because Leiphart cannot bring claims on behalf

of his son, any such claims are subject to dismissal. B. The Court cannot issue injunctive relief in the absence of a complaint.

This case should be dismissed because Leiphart has not filed a complaint; he has only filed a motion for preliminary injunctive relief. Thus, Leiphart has not filed the document necessary to commence a civil action. See Fed. R. Civ. P. 3 (“A civil action is commenced by filing a complaint with the court.”). Furthermore, the Court does not have the authority to issue injunctive relief in the absence of a properly- filed complaint. See Powell v. Rios, 241 F. App’x 500, 505 n.4 (10th Cir. 2007)

(“Absent a properly-filed complaint, a court lacks power to issue preliminary injunctive relief.”); Alabama v. U.S. Army Corps of Eng’rs, 424 F.3d 1117, 1134 (11th Cir. 2005) (“injunctive relief must relate in some fashion to the relief requested in the complaint”). Accordingly, because Leiphart has not filed a complaint, the Court cannot issue the injunctive relief he seeks and this case should be dismissed.

C. Younger bars this Court from interfering with ongoing state dependency proceedings.

Even assuming Leiphart had filed a complaint, the injunctive relief he seeks is subject to dismissal under Younger v. Harris, 401 U.S. 37 (1971). “The Younger doctrine bars federal court intervention in state noncriminal proceedings where the proceedings constitute an ongoing state judicial proceeding, the proceedings implicate important state interests, and there is an adequate opportunity in the state proceedings to raise constitutional challenges.” Adams v. State of Florida, 185 F. App’x 816, 816-17 (11th Cir. 2006) (citing 31 Foster Children v. Bush, 329 F.3d

1255, 1274 (11th Cir. 2003)). Here, all the Younger elements are met. First, the state dependency proceedings in Santa Rosa County Case No.

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LEIPHART v. FIRST FAMILIES NETWORK, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leiphart-v-first-families-network-flnd-2025.