Njogu v. Kagotho

CourtDistrict Court, E.D. Missouri
DecidedAugust 21, 2024
Docket4:24-cv-00944
StatusUnknown

This text of Njogu v. Kagotho (Njogu v. Kagotho) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Njogu v. Kagotho, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

FRANCIS M. NJOGU,1 ) ) Plaintiffs, ) ) v. ) No. 4:24-CV-00944 SPM ) CATHERINE KYAKIO KAGOTHO, ) ) Defendant. )

OPINION, MEMORANDUM AND ORDER

Before the Court is plaintiff Francis Njogu’s motion for leave to proceed in forma pauperis in this civil action. [ECF No. 2]. The Court will grant the motion to proceed in forma pauperis in this action. Furthermore, based upon a review of the complaint, the Court finds that the complaint should be dismissed pursuant to 28 U.S.C. § 1915(e)(2)(B). Legal Standard on Initial Review This Court is required to review a complaint filed in forma pauperis to determine whether summary dismissal is appropriate. See 28 U.S.C. § 1915(e). This Court must dismiss a complaint or any portion of it that states a frivolous or malicious claim, that fails to state a claim upon which relief may be granted, or that seeks monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2). An action is frivolous if it “lacks an arguable basis in either law or fact.” Neitzke v. Williams, 490 U.S. 319, 328 (1989). An action fails to state a claim upon which relief may 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).

1The Clerk spelled plaintiff’s last name as “Mjogu” on the Court docket. However, after review of the record, as well as Missouri Case.net, it is apparent that plaintiff’s last name is properly spelled “Njogu.” The Court will instruct the Clerk to update the docket with the proper spelling of plaintiff’s last name. A claim is facially plausible when the plaintiff “pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009). Determining whether a complaint states a plausible claim for relief is a context-specific task that requires the reviewing court to draw upon judicial experience

and common sense. Id. at 679. The court must assume the veracity of well-pleaded facts, but need not accept as true “[t]hreadbare recitals of the elements of a cause of action, supported by mere conclusory statements.” Id. at 678 (citing Twombly, 550 U.S. at 555). See also Barton v. Taber, 820 F.3d 958, 964 (8th Cir. 2016) (courts must “accept as true the facts alleged, but not legal conclusions or threadbare recitals of the elements of a cause of action, supported by mere conclusory statements.”). This Court liberally construes complaints filed by laypeople. Estelle v. Gamble, 429 U.S. 97, 106 (1976). “Liberal construction” means that “if the essence of an allegation is discernible,” the court should “construe the complaint in a way that permits the layperson’s claim to be considered within the proper legal framework.” Solomon v. Petray, 795 F.3d 777, 787 (8th Cir.

2015) (quoting Stone v. Harry, 364 F.3d 912, 914 (8th Cir. 2004)). However, even complaints filed by self-represented persons must allege facts that, if true, state a claim for relief as a matter of law. Martin v. Aubuchon, 623 F.2d 1282, 1286 (8th Cir. 1980). Federal courts are not required to assume facts that are not alleged, Stone, 364 F.3d at 914-15, and are not required to interpret procedural rules to excuse mistakes by those who proceed without counsel. See McNeil v. United States, 508 U.S. 106, 113 (1993). The Complaint Plaintiff Francis Njogu is a self-represented litigant who brings this civil action pursuant to 42 U.S.C. § 1983 against the mother of his minor child, Catherine Kagotho. Plaintiff and defendant are both residents of the State of Missouri.

From review of the complaint, as well as the documents attached to the complaint, it appears that plaintiff and defendant are parents of fourteen (14) year-old female child, E.W.M. Plaintiff acknowledges that he lost custodial rights to his child in May of 2019.2 Despite losing custody of his daughter in 2019, plaintiff brings the present action asserting that his child’s custodial parent is attempting to apply for a passport for his child, E.W.M., without his permission. He claims that he not only contacted the St. Louis Family Court to let the Judge presiding over his Parenting Plan know of the issue, but he also registered with the State Department to block defendant Kagotho’s attempts to get his daughter a passport.3 Plaintiff seeks injunctive relief in this action. Discussion

The crux of this case relates to child custody matters, and this Court lacks jurisdiction over child custody matters under the domestic relations exception to federal court jurisdiction. This exception, first recognized by the United States Supreme Court in Barber v. Barber, 62 U.S. 582, 603 (1858), “divests the federal courts of jurisdiction over any action for which the subject is a

2Plaintiff filed a second action in this Court against the Family Court of St. Louis City in which he laments the loss of his custodial rights. See Mjogu [sic] v. Family Court of Saint Louis Circuit Court, No. 4:24-CV- 01122 MTS (E.D.Mo.); see also See E.W.M., et al. v. Njogu, No. 14SL-DR07463-03 (21st Jud. Cir., St. Louis County Court).

3According to plaintiff he registered with the State Department’s Children’s Passport Issuance Alert Program, in which he swore, by signing the form seeking to prohibit his daughter from obtaining a passport, that he was “a concerned parent of [a] U.S. citizen child[], [her] appointed agent[], or other person[] having legal custody of the child.” divorce, allowance of alimony, or child custody.” Kahn v. Kahn, 21 F.3d 859, 861 (8th Cir. 1994) (citation omitted). As the Supreme Court later explained in Ex parte Burrus, “[t]he whole subject of the domestic relations of husband and wife, parent and child, belongs to the laws of the states, and not to the laws of the United States.” 136 U.S. 586, 593-94 (1890). Even “when a cause of

action closely relates to but does not precisely fit into the contours of an action for divorce, alimony or child custody, federal courts generally will abstain from exercising jurisdiction.” Kahn, 21 F.3d at 861. Furthermore, although plaintiff Njogu seeks an injunction from this Court to stop defendant Kagotho from applying from a passport for their daughter, the Court notes that plaintiff has acknowledged that he lacks custody over his daughter, while defendant has maintained full custody since 2019.

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Related

Barber v. Barber Ex Rel. Cronkhite
62 U.S. 582 (Supreme Court, 1859)
In Re Burrus
136 U.S. 586 (Supreme Court, 1890)
Estelle v. Gamble
429 U.S. 97 (Supreme Court, 1976)
Neitzke v. Williams
490 U.S. 319 (Supreme Court, 1989)
McNeil v. United States
508 U.S. 106 (Supreme Court, 1993)
Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Linda S. Kahn v. Farrell Kahn
21 F.3d 859 (Eighth Circuit, 1994)
James Solomon v. Deputy U.S. Marshal Thomas
795 F.3d 777 (Eighth Circuit, 2015)
Barton Ex Rel. Estate of Barton v. Taber
820 F.3d 958 (Eighth Circuit, 2016)
Martin v. Aubuchon
623 F.2d 1282 (Eighth Circuit, 1980)

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Bluebook (online)
Njogu v. Kagotho, Counsel Stack Legal Research, https://law.counselstack.com/opinion/njogu-v-kagotho-moed-2024.