Tyler v. Supreme Judicial Court of Mass.

914 F.3d 47
CourtCourt of Appeals for the First Circuit
DecidedJanuary 28, 2019
Docket18-1256P
StatusPublished
Cited by40 cases

This text of 914 F.3d 47 (Tyler v. Supreme Judicial Court of Mass.) is published on Counsel Stack Legal Research, covering Court of Appeals for the First Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tyler v. Supreme Judicial Court of Mass., 914 F.3d 47 (1st Cir. 2019).

Opinion

KAYATTA, Circuit Judge.

This appeal arises from Heather Tyler's six-year-long legal battle to void two Massachusetts Superior Court conditions of probation imposed on the adult male who was convicted of statutory rape after impregnating her when she was a minor. The district court found that Tyler's suit was, in essence, an appeal from a state-court judgment, and that the district court therefore lacked jurisdiction to hear it under the Rooker - Feldman doctrine. 1 For the following reasons, we agree.

I.

In 2009, at age nineteen or twenty, Jamie Melendez impregnated fourteen-year-old Heather Tyler. 2 Tyler gave birth in 2010. Upon pleading guilty in state court to the statutory rape of Tyler, Melendez received a sentence of sixteen years of probation. As conditions of probation, the sentencing judge ordered Melendez to acknowledge paternity of the child and abide by all orders of the Massachusetts Probate and Family Court.

In August 2012, after learning that Melendez sought to obtain parental visitation rights in the Probate and Family Court, Tyler filed a motion with the criminal sentencing judge seeking reversal of the conditions of probation mentioned above. She objected to the conditions on the grounds that Melendez's compliance with them would bind her to an unwanted sixteen-year legal relationship with Melendez in the Probate and Family Court. She requested that Melendez instead pay criminal *49 restitution, rather than child support, to relieve her of the burden of continued engagement with him in family court. The sentencing court denied Tyler's request. Tyler also sought relief from a single justice of the Supreme Judicial Court of Massachusetts (SJC) pursuant to Mass. Gen. Laws ch. 211, § 3 . After the single justice denied Tyler's motion, and Tyler appealed, the full SJC held oral argument on Tyler's claims. The SJC affirmed the decision of the single justice on the grounds that, as a victim of a criminal offense, Tyler lacked standing to challenge Melendez's criminal sentence. See H.T. v. Commonwealth , 465 Mass. 1011 , 989 N.E.2d 424 , 425 (2013). The SJC also advised that Tyler could "raise any claim of error, including any claim that the [Probate and Family Court] exceeded its lawful authority, in the ordinary appellate process." Id. at 426 .

Tyler then filed an action under the Federal Civil Rights Act, 42 U.S.C. § 1983 , in the District Court of Massachusetts, seeking review of substantially the same grievances. In November 2013, the district court dismissed the action as barred by the Eleventh Amendment. Tyler v. Massachusetts , 981 F.Supp.2d 92 , 96 (D. Mass. 2013). The court also noted that the Burford 3 and Younger 4 abstention doctrines counseled against adjudicating Tyler's claims. Id. at 96-97 . Tyler did not appeal.

In November 2013, Tyler filed a motion in the Probate and Family Court seeking either to vacate the court's jurisdiction or to terminate Melendez's parental rights. She contended that an adult convicted of statutory rape should have no parental rights with respect to a child born as a result of that crime. After the family court denied her motion, Tyler sought review in the Appeals Court of Massachusetts. The Appeals Court affirmed, holding that "nothing in the language of [the family court statute, Mass. Gen. Laws ch. 209C,] expressly limits its applicability solely to children born as a result of lawful intercourse." H.T. v. J.M. , No. 15-P-1042, 90 Mass.App.Ct. 1118 , 2016 WL 7046435 , at *2 (Mass. App. Ct. Dec. 5, 2016), appeal denied , --- Mass. ----, 75 N.E.3d 1130 (2017). The Appeals Court also discussed a 2014 amendment to the Massachusetts family court statute, 5 reasoning that since it was "apparent from [the amendment's] language that it was designed to limit, rather than to expand, the court's existing authority," the statute must have previously authorized family courts to adjudicate the parental rights of a parent convicted of statutory rape. Id. Finally, the Appeals Court denied Tyler's plea to vacate jurisdiction as a matter of public policy, noting that "the mother's desired disposition [would] require us to treat the father more favorably than other biological fathers, [and] it also would unfairly disadvantage the child by depriving her of the right to receive financial support from both parents." Id. at *3. In 2017, the SJC denied Tyler's application for further appellate review. See H.T. v. J.M. , 75 N.E.3d 1130 (Mass. 2017).

*50 Rather than seeking a writ of certiorari from the United States Supreme Court, Tyler filed this action in the District of Massachusetts, alleging that the "recent ruling of the Massachusetts Supreme Judicial Court" violated her Fourth and Fourteenth Amendment rights to due process, privacy, and equal protection.

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