Tenth Circuit Reaffirms the Rooker-Feldman Doctrine Bars State Court Losers from Asserting § 1983 Claims
On February 5th, 2025, the Tenth Circuit rendered its opinion in Moore v. Hebert, et al., No. 24-3092, arising out of the District of Kansas, from Judge Robinson, FPS&S’ Andrew Holder assisted by Connor Russo represented the defendant. Therein, the Court of Appeals affirmed the decision of the District Court, finding that absolute prosecutorial immunity and judicial immunity remains strong law—and further applies to assistants to the judicial function.
Plaintiff, Maurice Bernard Moore, pled guilty in 1986 to aggravated battery against a law enforcement officer and unlawful possession of a firearm. Roughly ten years later, in November of 1996, Moore filed a K.S.A. 60-1507 motion for new trial based on ineffective assistance of counsel. The state district court found Moore, setting aside his convictions and finding that his guilty plea was improperly accepted. Moore was returned to the Saline County Sheriff and held for re-trial on the charges from 1986. In January of 1997, the State filed amended information against Moore, to which Moore once again pled guilty, including an additional charge for misdemeanor concealed weapon. Moore was ultimately sentenced to 30 years to life.
Following direct appeal, which was originally denied by the Kansas Court of Appeals, and further denied for review by the Kansas Supreme Court, Moore filed a petition for writ of habeas corpus in federal court in 2000. Moore alleged that his second conviction constituted double jeopardy and that he should therefore not have been charged again. The District Court denied this petition, finding that jeopardy did not attach when he entered his plea because there was no evidence upon which the district court found him guilty. Moore appealed from the federal District Court’s ruling, but the Tenth Circuit found that Moore failed to make the showing necessary to obtain a certificate of appealability.
Then, on September 5, 2023, Moore filed a complaint for violation of civil rights against the former Saline County District Court Judge, the former Saline County District Attorney, his public defender, and Saline County. Moore alleged deprivation of his rights under 42 U.S.C. § 1983, along with claims under 18 U.S.C. § 241 and 4 (criminal conspiracy and misprision of a felony), and 18 U.S.C. § 1589 (criminal forced labor statute) against the individual defendants. Moore also brought a failure to supervise claim under Monell against the county. All parties moved to dismiss.
After hearing the parties’ motions, the District Court granted their motions to dismiss, finding that Moore’s claims were barred by the Rooker-Feldman doctrine and Heck v. Humphrey, 513 U.S. 477 (1984); that the Judge had judicial immunity; that the District Attorney had absolute prosecutorial immunity; that the public defender was not a state actor; and that Moore failed to plead a Monell claim against the county. Moore then timely appealed.
On Appeal, the Tenth Circuit affirmed the decision of the Court of Appeals, finding that the Rooker-Feldman doctrine deprived the Court of subject matter jurisdiction. Generally, the doctrine provides that a party who loses in state court “is barred from seeking what in in substance would be appellate review of the state judgment in a United States district court, based on the losing party’s claim that the state judgment itself violates the loser’s federal rights.” Moore v. Hebert, No. 24-3092, 2025 WL 400026 at *2 (10th Cir. Feb. 5, 2025) (citing Johnson v. De Grandy, 512 U.S. 997, 1005-06 (1994)). The doctrine is jurisdictional in nature. Id. (citing Campbell v. City of Spencer, 682 F.3d 1278, 1281 (10th Cir. 2012). The Court found that, based on Moore having lost in state court, he could not file a federal complaint seeking review and reversal of his unfavorable judgment. Accordingly, the Court lacked subject matter jurisdiction over Moore’s claims, and dismissal was appropriate.
Municipalities and their employees regularly face lawsuits from inmates and pretrial detainees based upon alleged violations of their civil rights. It is important to recognize certain remedies available for defeating such claims early, without having to undergo the heavy costs of litigation.
You can read the full opinion here: https://www.ca10.uscourts.gov/sites/ca10/files/opinions/010111184679.pdf