Stanley v. Finnegan

356 F. Supp. 3d 779
CourtDistrict Court, S.D. New York
DecidedDecember 3, 2018
DocketNo. 6:17-CV-06008
StatusPublished
Cited by1 cases

This text of 356 F. Supp. 3d 779 (Stanley v. Finnegan) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Stanley v. Finnegan, 356 F. Supp. 3d 779 (S.D.N.Y. 2018).

Opinion

P.K. HOLMES, III, CHIEF U.S. DISTRICT JUDGE

Before the Court is Separate Defendant Katherine Finnegan's motion (Doc. 46) for judgment on the pleadings and brief (Doc. 47) in support of her motion. Plaintiffs Hal and Michelle Stanley (collectively "the Stanleys") filed a response (Doc. 52) in opposition and a brief (Doc. 53) in support of their response. Finnegan filed a reply (Doc. 57) without leave of Court. Finnegan then filed a motion (Doc. 63) for leave to file a reply and a brief (Doc. 64) in support of her motion. The Court denied Finnegan's motion (Doc. 65) for leave and will not consider her reply. There is also pending a motion1 (Doc. 50) to adopt the pleadings *783filed by Separate Defendants Garland County, Arkansas, Mike McCormick, Jason Lawrence, Mike Wright and Terry Threadgill.

The Stanleys brought damages claims pursuant to 42 U.S.C. § 1983 against various Arkansas officials, including Katherine Finnegan, individually and in her official capacity as an investigator in the Crimes Against Children Division (CACD) of the Arkansas State Police (ASP), for injuries caused by the alleged unlawful removal of their seven children by Arkansas Department of Human Services (DHS). Prior to the instant motion, Finnegan, among others, filed motions to dismiss (Docs. 19, 21, & 22) the Stanleys' claims on qualified immunity, collateral-attack, and state preclusion grounds. The Court granted the motion2 with respect to all claims against Finnegan based on qualified immunity except the claim alleging "that she removed Plaintiffs' minor children from their home without an adequate basis."3 (Doc. 29, p. 10). Finnegan appealed the order and the Eighth Circuit Court of Appeal affirmed. (Doc. 51). Finnegan filed this Rule 12(c) motion for judgment on the pleadings arguing that the Stanleys' remaining claim against her should be dismissed as a matter of law because (1) the Court lacks subject-matter jurisdiction pursuant to the Rooker-Feldman abstention doctrine; (2) the Stanleys lack Article III standing; (3) the remaining claim is a collateral-attack on state court proceedings; and (4) the remaining claim is barred by res judicata and collateral estoppel. For the reasons set forth below, Finnegan's motion will be denied.

I. Legal Standard

When considering a Rule 12(c) motion for judgment on the pleadings, the Court uses the same standard as that for a motion to dismiss for failure to state a claim under Rule 12(b)(6). Ashley Cnty., Ark. v. Pfizer, Inc. , 552 F.3d 659, 665 (8th Cir. 2009). Judgment on the pleadings is appropriate "only if the moving party clearly establishes that there are no material issues of fact and that it is entitled to judgment as a matter of law. Porous Media Corp. v. Pall Corp. , 186 F.3d 1077, 1079 (8th Cir. 1999). The Court must "accept as true all facts pleaded by the non-moving party and grant all reasonable inferences from the pleadings in favor of the non-moving party." Gallagher v. City of Clayton , 699 F.3d 1013, 1016 (8th Cir. 2012) (quoting United States v. Any & All Radio Station Transmission Equip. , 207 F.3d 458, 462 (8th Cir. 2000) ). "[A] complaint must contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face." Ashcroft v. Iqbal , 556 U.S. 662, 678, 129 S.Ct. 1937, 173 L.Ed.2d 868 (2009) (internal quotations omitted). Pleadings that contain mere "labels and conclusions" or "a formulaic recitation of the elements of the cause of action will not do."

*784Bell Atlantic Corp. v. Twombly , 550 U.S. 544, 555, 127 S.Ct. 1955, 167 L.Ed.2d 929 (2007).

II. Discussion

At the outset, the Stanleys assert Finnegan's arguments of issue preclusion, claim preclusion, and collateral-attack should be struck under Rule 12(f) as redundant because the Court ruled on the same issues in Finnegan's earlier Rule 12(b)(6) motion and Finnegan failed to appeal those grounds. The Court previously denied Finnegan's motion to dismiss on these grounds because the arguments were, at that time, unsupported by the record. Finnegan has since supplemented her Rule 12(c) motion with additional factual allegations and documents specifically in regard to the remaining claim against her. Moreover, the Court's earlier decision on these grounds was not subject to interlocutory review. Plaintiffs offer no legal support for the proposition that Finnegan is prohibited from raising these arguments in her Rule 12(c) motion under these circumstances. The Court will therefore address each of Finnegan's claims.

A. Rooker-Feldman Doctrine

Finnegan argues that the Court lacks subject-matter jurisdiction over the Stanleys' claim pursuant to the Rooker-Feldman doctrine. Because Rooker-Feldman implicates a jurisdictional question, it must be addressed at the outset. Silverman v. Silverman , 338 F.3d 886, 893 (8th Cir. 2003). The Rooker-Feldman abstention doctrine precludes a district court from reviewing any final state court decision on the merits, because "federal jurisdiction to review most state court judgments is vested exclusively in the United States Supreme Court." Simes v. Huckabee , 354 F.3d 823, 827 (8th Cir. 2004) (quoting

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356 F. Supp. 3d 779, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stanley-v-finnegan-nysd-2018.