Tuesday, May 30, 2006

D. Conn. Finds Civil Rights Claim “Inextricably Intertwined” with Past Juvenile Court Proceedings and Thus Barred by Rooker-Feldman Doctrine

Per Inkel v. Connecticut Dept. of Children and Families, 421 F.Supp.2d 513 (D.Conn. Mar 17, 2006):

Plaintiffs claim that the orders of temporary custody that were entered for [their children] were obtained by fraud and false testimony presented by D.C.F. [Department of Children and Families] employees and accepted and condoned by defendants Pellegrino and Pisani, a deputy clerk for the Connecticut Superior Court for Juvenile Matters at Waterford. Defendants argue that claims arising out of false testimony or false affidavits are barred by the Rooker-Feldman doctrine, and the Court agrees.

“Rooker-Feldman applies not only to decisions of the highest state courts, but also to decisions of lower state courts.” Ashton v. Cafero, 920 F.Supp. 35, 37 (D.Conn.1996). It applies to “challenges to final and interlocutory state court decisions.” Id. (emphasis added).

Here, plaintiffs' claims that D.C.F. personnel submitted false evidence and thereby obtained unwarranted orders of temporary custody over the children are “inextricably intertwined” with the juvenile court proceedings themselves. The state court judges who issued the custody orders evidently credited the information presented by D.C.F. Plaintiffs now ask this Court to second-guess the state courts' factual and credibility findings. Plaintiffs' remedy for an incorrect or unfair juvenile court decision is to appeal that decision to higher state courts, not to seek federal court intervention by way of a civil rights action. Therefore any claims brought under 42 U.S.C. § 1983 relating to the submission of false testimony or information to state court must be dismissed.


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