Williams v. Trosclair

CourtDistrict Court, E.D. Louisiana
DecidedSeptember 14, 2022
Docket2:22-cv-00220
StatusUnknown

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

Bluebook
Williams v. Trosclair, (E.D. La. 2022).

Opinion

EASTERN DISTRICT OF LOUISIANA

ABRYANT D. WILLIAMS CIVIL ACTION VERSUS NO. 22-220 AMANDA TROSCLAIR et al. SECTION: “G”(3)

ORDER AND REASONS

This litigation arises from state court child support enforcement proceedings in the Twenty- Second Judicial District Court for the Parish of St. Tammany, State of Louisiana.1 Pending before the Court is a Motion to Dismiss2 filed by Defendant Amanda Trosclair (“Trosclair”), a hearing officer for the Twenty-Second Judicial District Court. Pro se Plaintiff Abryant D. Williams (“Plaintiff”) opposes the motion.3 For the reasons discussed in detail below, the Court finds that Plaintiff seeks to void a state court order of child support payments and compel Defendants to relitigate the child support enforcement proceedings. Therefore, this Court is barred from hearing Plaintiff’s claims against Trosclair. Accordingly, considering the motion, the memoranda in support and opposition, the record, and the applicable law, the Court grants Trosclair’s motion to dismiss and dismisses Plaintiff’s claims without prejudice.

1 See Rec. Doc. 1. 2 Rec. Doc. 17. 3 Rec. Doc. 24. On January 31, 2022, Plaintiff filed this action under 42 U.S.C. § 1983, alleging that several

Louisiana state employees and agencies violated his civil rights in the course of child support enforcement proceedings.4 On May 2, 2022, Plaintiff filed an Amended Complaint.5 Plaintiff named Hearing Officer Trosclair, Assistant District Attorney Mary T. Strahan (“Strahan”), Child Support Analyst Robert Trahan (“Trahan”), Minute Clerk Kendra Davis (“Davis”), the Louisiana Department of Child and Family Services (“DCFS”), and the State of Louisiana as Defendants (collectively, “Defendants”).6 Plaintiff asserts that all of the Defendants contributed to the events of the child support enforcement proceeding underlying his § 1983 claim.7 Plaintiff avers that the child support enforcement hearing commenced on April 6, 2021 in a video conference.8 Plaintiff alleges that Trosclair, the presiding official as hearing officer, halted the video hearing and ordered Plaintiff to appear at the courthouse for the Twenty-Second Judicial District Court.9

Plaintiff alleges that he was handcuffed upon arrival to the courthouse and told by Davis that he would be jailed if he did not sign the child support order.10 Plaintiff further claims that law enforcement officers were sent to arrest him to enforce the child support orders in July 2021.11 Plaintiff argues that the state child support order and attempts to enforce the order have violated

4 Rec. Doc. 1. 5 Rec. Doc. 8. 6 Rec. Doc. 1. 7 Id. at 2, 3, 11. 8 Rec. Doc. 8 at 9. 9 Id. 10 Id. 11 Id. at 10. his VA benefits.”12 Plaintiff alleges that Defendants’ violated his due process rights through their

“racist” and “aggressive and abusive treatment” at the courthouse on April 6, 2021.13 Specifically, Plaintiff argues that the act of handcuffing him upon arrival to the Courthouse and compelling him to sign the order in order to avoid jail time constituted “overt racist aggression against the Plaintiff.”14 Plaintiff requests that this Court grant declaratory and injunctive relief from the state court enforcement proceedings.15 Plaintiff also seeks punitive damages.16 On July 18, 2022, Trosclair filed the instant motion to dismiss.17 Pursuant to Local Rule 7.5, any opposition to a motion was due eight days before the noticed submission date.18 Thus, Plaintiff’s opposition to Trosclair’s Motion was due on August 2, 2022. Plaintiff filed an untimely opposition to the motion on August 30, 2022.19 Nevertheless, considering Plaintiff’s pro se status,

the Court exercises its discretion to consider the untimely arguments made in opposition to the motion to dismiss. On September 7, 2022, Trosclair filed a reply memorandum in further support of her motion to dismiss.20

12 Id. at 3, 9. 13 Id. at 10. 14 Id. 15 Id. 16 Id. at 15. 17 Rec. Doc. 17. 18 EDLA Local Rule 7.5. 19 Rec. Doc. 24. 20 Rec. Doc. 25. A. Trosclair’s Arguments in Support of the Motion to Dismiss

Trosclair advances six arguments in support of her motion to dismiss.21 First, Trosclair argues that the doctrine of judicial immunity bars Plaintiff’s claims for damages.22 Trosclair argues that judicial immunity applies to her actions as hearing officer because Louisiana law vests hearing officers with authority to “hear and make recommendations . . . on establishment and modification of [child support] . . . on the method of collection . . . [and] on enforcement of [child support].”23 Trosclair contends that neither of the exceptions to the application of judicial immunity are present in this case, arguing that she acted within her grant of jurisdiction as the presiding officer over the child support enforcement action underlying Plaintiff’s claim.24 As such, Trosclair argues that she is entitled to judicial immunity.25

Second, Trosclair argues that Plaintiff’s claims should be dismissed pursuant to the Rooker- Feldman doctrine.26 Trosclair claims that the Rooker-Feldman doctrine applies to prevent collateral attacks on state court judgments brought by unsuccessful state court litigants.27 Trosclair contends that Plaintiff “cannot circumvent” the doctrine by “casting [his complaint] in the form of a civil rights action.”28 Accordingly, Trosclair argues that this Court lacks subject matter

21 See Rec. Doc. 17-1. 22 Id. at 3–5. 23 Id. at 4–5 (quoting La. R. S. 46:236.5(C)(1)(a-c)). 24 Id. 25 Id. 26 Id. at 5. 27 Id. 28 Id. (quoting Liedtke v. State Bar of Tex., 18 F.3d 315, 317 (5th Cir. 1994)). orders requiring him to pay child support.29

Third, Trosclair argues that Plaintiff’s claims should be dismissed pursuant to the Younger abstention doctrine.30 Trosclair contends that Plaintiff’s claims “would require this Court to issue relief either challenging orders and judgments that are not yet final, or otherwise interfering with ongoing state court enforcement proceedings.”31 Trosclair avers the present litigation interferes with the State of Louisiana’s “strong interest in ensuring that Louisiana child support orders are enforced.”32 Additionally, Trosclair contends that Louisiana law provides adequate opportunity to raise constitutional challenges in state proceedings after a timely objection is made.33 Thus, Trosclair argues that this Court should abstain from hearing Plaintiff’s claims pursuant to the Younger abstention doctrine.34

Fourth, Trosclair avers that the domestic relations doctrine bars Plaintiff’s claims.35 Trosclair asserts that the domestic relations doctrine bars federal courts from “issuing or modifying ‘a divorce, alimony, or child custody decree.’”36 Trosclair claims that Plaintiff “seeks to have this Court declare that prior support orders cannot be satisfied out of his benefits” and thereby

29 Id. at 6. 30 Id. at 7. 31 Id. 32 Id. at 8. 33 Id. at 9–10. 34 Id. at 10. 35 Id. 36 Id. (citing Saloom v. Texas Dep’t of Family & Child Protective Servs., 578 Fed. App’x 426, 429–30 (5th Cir. 2014)). should dismiss Plaintiff’s claims pursuant to the domestic relations exception to federal

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Williams v. Trosclair, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-trosclair-laed-2022.