Ronald Liedel and Elizabeth Liedel v. The Juvenile Court of Madison County, Alabama, and the Alabama Department of Human Resources

891 F.2d 1542, 1990 U.S. App. LEXIS 414, 1990 WL 39
CourtCourt of Appeals for the Eleventh Circuit
DecidedJanuary 16, 1990
Docket89-7235
StatusPublished
Cited by62 cases

This text of 891 F.2d 1542 (Ronald Liedel and Elizabeth Liedel v. The Juvenile Court of Madison County, Alabama, and the Alabama Department of Human Resources) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Ronald Liedel and Elizabeth Liedel v. The Juvenile Court of Madison County, Alabama, and the Alabama Department of Human Resources, 891 F.2d 1542, 1990 U.S. App. LEXIS 414, 1990 WL 39 (11th Cir. 1990).

Opinion

JOHNSON, Circuit Judge:

This case arises on appeal from the district court’s dismissal of plaintiffs’ section 1983 complaint on February 14, 1989, and the court’s denial of their March 2, 1989, Rule 59(e) Motion to Alter, Amend or Vacate Judgment. 707 F.Supp. 486. We affirm.

I. FACTS

In their complaint, Ronald and Elizabeth Liedel (“the Liedels”) alleged that the Madison County, Alabama Department of Human Resources (“the Department”) and the Juvenile Court of Madison County, Alabama (“the Juvenile Court”), violated the Liedels’ constitutional rights to due process and privacy. The Liedels objected to child custody proceedings brought by the Department in the Juvenile Court, which is a state court in the Alabama judicial system. The Liedels sought relief from the Juvenile *1544 Court’s prior rulings against them, an injunction prohibiting the Juvenile Court from continuing to hear the child custody proceeding against them, and damages from the Department.

A. State Court Proceedings

In late 1987, the Department filed a child custody petition with the Juvenile Court, naming Elizabeth as a party. The petition alleged that her husband, Ronald, was physically and emotionally abusing Elizabeth’s son, Charles Sullivan. 1 Elizabeth was served with a summons, but Ronald was not. 2

On the same day that the petition was filed, the clerk of the Juvenile Court supplied Elizabeth with a preprinted “Notification Of Right To Counsel” form, explaining her right to counsel in the child custody proceeding. Elizabeth filed an affidavit of indigency on January 5, 1988, but on the advice of Ronald, she did not include any of Ronald’s assets in the affidavit. The Juvenile Court denied her request for appointed counsel “based on incomplete and inaccurate information given by the applicant.”

The Juvenile Court held a hearing on January 26, 1988. The Juvenile Court explained to Elizabeth that as the natural mother of the child she, and not Ronald, was a party to the action and that, as the party, the decision whether to have counsel was hers. Elizabeth did not retain an attorney, and Ronald assisted her in her presentation at the hearing.

Based on his participation in the hearing, the Juvenile Court held that Ronald had made himself a party to the proceedings and would be bound by any holding of the Court. After the January 26, 1988 hearing, the Juvenile Court entered an order committing temporary legal custody of Charles to the Department, 3 ordering Ronald, Elizabeth and Charles to attend family counseling, and taxing costs to Ronald and Elizabeth. On February 10, 1988, Ronald filed a motion with the Juvenile Court to alter, amend or vacate its judgment. The motion claimed that Ronald was not a party to the action, that he was never served, that the Juvenile Court lacked jurisdiction over him, and that he was not financially responsible for Charles. The Juvenile Court denied this motion on February 11, 1988. Ronald appealed the Juvenile Court’s decision by filing a writ of mandamus with the Alabama Court of Civil Appeals. The Court of Civil Appeals upheld the Juvenile Court’s denial, Ex parte Liedel, 534 So.2d 624 (Ala.Civ.App.1988), and Ronald applied for certiorari to the Alabama Supreme Court. This application was denied on December 2, 1988.

On February 10, 1989, the Juvenile Court ordered the Liedels to appear at a hearing on February 24, 1989, for the purpose of reporting their compliance with the Juvenile Court’s prior orders.

B. Federal District Court Proceedings

The Liedels filed this action in the United States District Court on February 14, 1989, four days after the Juvenile Court had ordered the February 24, 1989 hearing. Their complaint asked for a temporary restraining order and a permanent injunction against the Department and Juvenile Court, preventing them from enforcing the Juvenile Court’s prior orders and preventing them from issuing further orders against the Liedels. The complaint alleged that the child custody action violated Ronald’s constitutional rights because Ronald was not a party to the action, was never served, was not subject to the Juvenile Court's jurisdiction, and was not financially responsible for Charles. The complaint also alleged that the Juvenile Court deprived Elizabeth of her right to counsel by denying her appointed counsel in the child custody proceedings and by permitting *1545 Ronald to participate in the January 26, 1988 hearing. On February 14, 1989, the district court denied their motion for a temporary restraining order and dismissed their complaint because the Liedels’ allegations failed to trigger the district court’s jurisdiction. In a memorandum opinion dated March 2, 1989, the district court denied the Liedels’ Rule 59(e) motion to alter, amend or vacate the February 14 judgment. The district court held that principles of equity, comity, and federalism prevented the district court from enjoining the state court proceeding through a section 1983 action, and that the Liedels should pursue their federal constitutional claims through direct appeal of the state court judgment.

The Liedels appeal the district court’s dismissal of their complaint. We hold that the Liedels’ complaint does not fall within the jurisdiction of the federal district court because it seeks to void a final state court judgment, Rooker v. Fidelity Trust Co., 263 U.S. 413, 44 S.Ct. 149, 68 L.Ed. 362 (1923), and because it seeks to enjoin ongoing state proceedings. Younger v. Harris, 401 U.S. 37, 91 S.Ct. 746, 27 L.Ed.2d 669 (1971).

II. ANALYSIS

A. Effect of the Rooker-Feldman Doctrine

In Rooker v. Fidelity Trust Co., 263 U.S. 413, 44 S.Ct. 149, 68 L.Ed. 362 (1923), the Supreme Court held that a federal district court may not review the final decisions of a state court of competent jurisdiction. Such review rests solely in the United States Supreme Court. The Supreme Court reaffirmed this principle in District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 482 & n. 16, 103 S.Ct. 1303, 1315 & n. 16, 75 L.Ed.2d 206 (1983). The Feldman Court stated,

[LJower federal courts possess no power whatever to sit in direct review of state court decisions. If the constitutional claims presented to a United States district court are inextricably intertwined with the state court’s denial [of a claim] in a judicial proceeding ... then the district court is in essence being called on to review the state-court decision. This the district court may not do.

Id. at 483-84 n. 16, 103 S.Ct. at 1315-16 n. 16. In

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891 F.2d 1542, 1990 U.S. App. LEXIS 414, 1990 WL 39, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ronald-liedel-and-elizabeth-liedel-v-the-juvenile-court-of-madison-county-ca11-1990.