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MEMORANDUM OPINION
1
In light of the finding that the Rooker-Feldman doctrine
precludes subject matter jurisdiction, this opinion does not
address the defendant’s alternative argument that the doctrine
of Younger v. Harris, 401 U.S. 37 (1971), requires abstention
from interfering in ongoing proceedings in District of Columbia
courts.
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BACKGROUND
alleges that Judge Bayly made improper findings that Araya had
§ 2202, and the DCHRA, asserting that Judge Bayly violated the
2
Araya’s amended complaint has two separate sections
labeled as Count Three.
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the trial (id. ¶ 15), and statements and rulings on motions (id.
to warrant abstention.
DISCUSSION
has been long accepted that the [court] may make appropriate
motion. Haase v. Sessions, 835 F.2d 902, 906 (D.C. Cir. 1987)
The Supreme Court has made clear that lower federal courts
also Lance v. Dennis, 546 U.S. 459, 463 (2006) (emphasizing that
28 U.S.C. § 1257 vests the Supreme Court, and not the lower
v. Poole, 275 F.3d 1113, 1119 (D.C. Cir. 2002), and that the
to “cases of the kind from which the doctrine acquired its name:
Wilmore, 407 F.3d 274, 279 (4th Cir. 2005) (quoting Feldman, 460
the state court wrongly decided the issues before it.’” Phyler
v. Moore, 129 F.3d 728, 731 (4th Cir. 1997) (quoting Charchenko
v. D.C. Court of Appeals, 127 F.3d 72, 75-76 (D.C. Cir. 1997);
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Supp. 2d 94, 100 (D.D.C. 2010), aff’d, 407 F. App’x 489 (D.C.
result was based on a legal error, the proper response [is] the
same one open to all litigants who are unhappy with the judgment
that Araya does not seek “[d]irect review of Judge Bayly’s final
possessed jurisdiction.
divorce and child support, DeGroot v. DeGroot, 939 A.2d 664, 668
August 24, 2011 Order), plainly had the requisite subject matter
jurisdiction to do so.
the judge before whom his matter is assigned has personal bias
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3
Araya mistakenly relies on case law regarding 28 U.S.C.
§ 144, which governs the recusal of federal district judges.
That statute provides no basis for federal district court review
of Judge Bayly’s qualifications to preside over Araya’s case.
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4
Araya also contends that the Rooker-Feldman doctrine does
not apply to this suit because “the defendant, Judge Bayly, is
different than [the defendant in] my case in the Superior
Court.” (Pl.’s Opp’n at 6.) Araya relies on Lance v. Dennis,
546 U.S. 459 (2006), which held there was no bar to a federal
action brought by plaintiffs who were not parties to a prior
state court action that resulted in the state court’s approval
of a legislative redistricting plan and who, as non-parties,
could not appeal the judgment in the state case. Araya was
himself a party to the Superior Court proceedings underlying
this federal action and can challenge the Superior Court’s
decision by means of appeal in District of Columbia courts.
That he brings this action against Judge Bayly, rather than
against the defendant in the Superior Court case (his ex-wife),
does not alter the fundamental fact that the case seeks review
of a local court judgment. See, e.g., Brown, 1997 WL 150101, at
*1 (dismissing challenge to divorce proceedings brought against
state judge and others under Rooker-Feldman doctrine); Wall v.
Wall, No. 2:09-cv-527-MEF, 2009 WL 3110208, at *1 (M.D. Ala.
Sep. 24, 2009) (same).
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CONCLUSION
__________/s/_______________
RICHARD W. ROBERTS
United States District Judge