Automated Summary
Key Facts
Plaintiff DeAndre L. Blair, proceeding pro se, sued Racine County Child Support officials for alleged constitutional violations related to child support and paternity proceedings. This is the third time Blair has filed cases seeking to collaterally attack state court judgments regarding his custody, child support obligations, or paternity. The Court dismissed the action with prejudice and imposed a five-year filing bar that precludes Plaintiff from filing any paper in this District that seeks to collaterally attack state court proceedings. The dismissal is based on the domestic-relations exception to federal jurisdiction and the Rooker-Feldman doctrine.
Issues
- The court addresses whether to dismiss the plaintiff's claims and whether to impose a filing restriction given the plaintiff's pattern of filing meritless lawsuits attacking state court proceedings. The court finds that the plaintiff's pro se status does not insulate him from sanctions and imposes a five-year bar on filing papers seeking to collaterally attack state court proceedings.
- The court dismisses the plaintiff's claims as failing to state a claim and barred by the domestic-relations exception to federal jurisdiction and the Rooker-Feldman doctrine, which prevents federal courts from reviewing state court judgments. The court also imposes a five-year filing bar on the plaintiff, who has filed three similar cases seeking to attack state court judgments regarding custody, child support, or paternity, as a sanction for abusive litigation practices.
Holdings
The Court dismisses Plaintiff DeAndre L. Blair's action with prejudice. The Court also denies Plaintiff's motion for leave to proceed without prepayment of the filing fee as moot. Additionally, the Court imposes a five-year filing bar that precludes Plaintiff from filing any paper in any case in this District that seeks to collaterally attack any state court proceeding to which he is a party, including motions for reconsideration but excluding notices of appeal, papers related to exigent circumstances, or criminal cases where Plaintiff is a defendant or habeas corpus applications.
Remedies
- The Court dismisses Plaintiff DeAndre L. Blair's case with prejudice
- Plaintiff DeAndre L. Blair is barred from filing any paper in any case in this District that seeks to collaterally attack a state court proceeding to which he is a party, for a period of five (5) years from the date of this Order. This includes motions for reconsideration, but excludes notices of appeal, papers related to exigent circumstances, or applications for habeas corpus in criminal cases where he is a defendant.
Legal Principles
- The Rooker-Feldman doctrine bars federal courts from reviewing or challenging state court judgments, including claims challenging state court judgments that imposed child support obligations or were used to garnish wages, place liens, or result in jail time.
- The All Writs Act and inherent powers of federal courts allow district courts to fashion sanctions for conduct that abuses the judicial process, including imposing filing restrictions on vexatious litigants who repeatedly file meritless lawsuits based on the same facts. The court imposed a five-year filing bar on Plaintiff for collaterally attacking state court proceedings.
- The domestic-relations exception to federal jurisdiction prevents federal courts from hearing cases that challenge child support payments or paternity obligations, as these matters fall within the exclusive jurisdiction of state courts in family law matters.
Precedent Name
- Chambers v. NASCO, Inc.
- Chapman v. Exec. Comm. of U.S. Dist. Ct. for N. Dist. of Ill.
- Molski v. Evergreen Dynasty Corp.
- Ritter v. Ross
- Support Sys. Intern., Inc. v. Mack
- In re Chapman
- Syph v. Arce
- Gillette v. Gillette
- Friedlander v. Friedlander
- Sato v. Plunkett
- Orlando Residence Ltd. v. GP Credit Co., LLC
- Mucha v. Wisconsin
- Johnson v. Lockyer
- Lewis v. Casey
- Lammers v. Ellerd
Cited Statute
- The All Writs Act
- Federal Rule of Civil Procedure 60(b)
- Federal Rules of Appellate Procedure 3, 4
- Federal Rule of Civil Procedure 59(e)
Judge Name
Judge J.P. Stadtmueller
Passage Text
- IT IS ORDERED that this action be and the same is hereby DISMISSED with prejudice; IT IS FURTHER ORDERED that Plaintiff DeAndre L. Blair's motion for leave to proceed without prepaying the filing fee, ECF No. 3, be and the same is hereby DENIED as moot; and IT IS FURTHER ORDERED that Plaintiff DeAndre L. Blair shall be BARRED from filing any paper in any case in this District that seeks to collaterally attack a state court proceeding to which he is a party, including any new lawsuits and any motions for reconsideration, but excluding notices of appeal or papers related to exigent circumstances or in any criminal case in which he is a defendant or any application for habeascorpus, for a period of five (5) years from the date of this Order.
- Under the circumstances presented by Plaintiff having filed three cases all premised on the same facts related to his state court child support and paternity proceedings, the Court finds it appropriate to impose a filing bar. Plaintiff will be barred from filing any paper in any case in this District that seeks to collaterally attack a state court proceeding to which he is a party, for a period of five (5) years from the date of this Order.
- Because the Court finds the reasoning sound for both previous orders dismissing Plaintiff's very same allegations, it will similarly dismiss Plaintiff's claims here as failing to state a claim and barred by the domestic-relations exception to federal jurisdiction and the Rooker-Feldman doctrine. It will accordingly dismiss Plaintiff's case. In light of the filing bar that the Court will impose, discussed below, the dismissal will operate with prejudice.