Arvie v. Cathedral of Faith: Clarifying Rooker–Feldman, Younger Abstention, and Immunity in Pro Se Civil Rights Litigation

Introduction

In Arvie v. Cathedral of Faith, the Fifth Circuit addressed the appeal of pro se plaintiff Hubert Arvie, whose in forma pauperis civil rights action against more than ninety defendants—ranging from state judges and court staff to private attorneys, insurance companies, a church and its pastors, and even Warren Buffett—had been dismissed by the district court. Arvie’s fifty-seven-page second amended complaint asserted claims under 42 U.S.C. §§1981, 1983, 1985(3), 1986, 1988, and 2201–2202, plus an array of state-law claims. He claimed violations of free exercise of religion, access to courts, equal protection, due process, and more. After the magistrate judge recommended dismissal on grounds of judicial and absolute immunity, Eleventh Amendment immunity, lack of state action by private parties, and failure to state a claim, the district court adopted those recommendations, denied further motions, and dismissed with prejudice. On June 3, 2025, a per curiam panel of the Fifth Circuit affirmed that dismissal.

Summary of the Judgment

• The court confirmed that Arvie’s complaint was properly dismissed under 28 U.S.C. §1915(e)(2)(B) as frivolous, failing to state a claim, or seeking relief against immune defendants.
• It held that the Rooker–Feldman doctrine did not bar jurisdiction because some state proceedings and appeals were ongoing when Arvie filed his federal suit; however, the Younger abstention doctrine justified dismissal of requests for injunctive and declaratory relief interfering with pending state proceedings.
• Arvie’s attempt to invoke 28 U.S.C. §1738 to compel state-court records was rejected—§1738 imposes no private right of action.
• The Fifth Circuit reaffirmed absolute judicial immunity for judges (and court staff acting at their direction) for all judicial and certain administrative acts, and Eleventh Amendment immunity for claims against the State and its employees in their official capacities.
• All §1983 claims against private parties were dismissed for failure to allege state action or conspiracy; Monell liability against Calcasieu Parish was barred by absence of any constitutional violation.
• Other motions—appointment of counsel, Spears hearing, leave to amend, recusal, injunction—were properly denied under settled standards.

Analysis

Precedents Cited

• 28 U.S.C. §1915(e)(2)(B) (Samford v. Dretke, 562 F.3d 674; Ashcroft v. Iqbal, 556 U.S. 662)
• Rooker–Feldman (Rooker v. Fid. Tr. Co., 263 U.S. 413; D.C. Court of Appeals v. Feldman, 460 U.S. 462; Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280)
• Younger (Younger v. Harris, 401 U.S. 37; Middlesex County Ethics Comm’n v. Garden State Bar Ass’n, 457 U.S. 423)
• Section 1738 rule of decision (Allen v. McCurry, 449 U.S. 90; Thompson v. Thompson, 484 U.S. 174)
• Absolute Judicial Immunity (Stump v. Sparkman, 435 U.S. 349; Malina v. Gonzales, 994 F.2d 1121)
• Eleventh Amendment Immunity (Kentucky v. Graham, 473 U.S. 159; McKinley v. Abbott, 643 F.3d 403)
• Municipal Liability (Monell) (Monell v. Dept. of Soc. Serv. of City of N.Y., 436 U.S. 658; Valle v. City of Houston, 613 F.3d 536)

Legal Reasoning

The court applied de novo review to the district court’s screening dismissal under §1915(e)(2)(B). It first distinguished Rooker–Feldman (which bars federal review of final state judgments) from Younger abstention (which requires federal courts to refrain from constitutional challenges to ongoing state proceedings). Because several state matters were still under appeal when Arvie sued, Rooker–Feldman did not apply; but Younger compelled abstention from injunctive or declaratory relief.

On §1738, the court reiterated that it provides no federal cause of action—merely a mechanism for authenticating state judicial records for full faith and credit.

The immunity analysis followed longstanding doctrine:

• Judges are absolutely immune for acts within their judicial capacity (Stump) and even for disciplinary acts under Codes of Judicial Conduct.
• Court clerks and staff are likewise immune when carrying out judicial duties (Tarter v. Hury).
• Eleventh Amendment bars suits for damages against states or their officials in official capacity (Kentucky v. Graham).
• Ex parte Young and the 1996 amendment to §1983 strip federal courts of authority to grant injunctive relief against judges acting in their judicial capacity absent violation of a declaratory decree.

On state-action under §1983, the court held that conclusory conspiracy assertions against private actors cannot supply the “color of law.” Monell claims also fail without an underlying constitutional deprivation or municipal policy.

Impact

This decision reinforces several critical principles for pro se litigants and district courts:

• Rigorous application of §1915(e)(2)(B) to bar meritless, immunity-barred civil rights suits.
• Clear delineation between Rooker–Feldman and Younger doctrines, emphasizing abstention where state proceedings are pending.
• Reaffirmation that §1738 does not create a private cause of action.
• Robust protection of judges, court staff, and state officials through absolute and sovereign immunities.
• Ongoing difficulty for private parties to be deemed state actors without specific factual allegations of concerted action with government.

Lower courts will cite Arvie when screening in forma pauperis civil rights complaints and when dealing with overlapping federal and state court jurisdiction and immunity defenses.

Complex Concepts Simplified

• In Forma Pauperis Screening (28 U.S.C. §1915): Federal courts can dismiss indigent plaintiffs’ suits if they are frivolous, fail to state a claim, or seek relief against immune defendants.
• Rooker–Feldman Doctrine: Bars federal district courts from reviewing final state court judgments; does not apply if appeals are pending.
• Younger Abstention: Federal courts abstain from interfering with ongoing state judicial proceedings through injunctive or declaratory relief.
• Absolute Judicial Immunity: Judges (and their essential staff) cannot be sued for damages for acts within their official judicial duties, even if alleged to be corrupt or malicious.
• Eleventh Amendment Immunity: States and state officials sued in their official capacity are immune from suits for damages under federal law.
• Monell Liability: Municipalities can be sued under §1983 only when a constitutional right is violated pursuant to an official policy or custom.

Conclusion

Arvie v. Cathedral of Faith underscores the high hurdles facing pro se civil rights plaintiffs. It clarifies that:

• State courts retain their autonomy through immunity doctrines and abstention rules.
• Section 1738 is not a free-standing cause of action.
• Federal courts must distinguish between jurisdictional bars (Rooker–Feldman) and abstention (Younger).
• Absolute and sovereign immunities remain potent shields for judges, court staff, and state actors.
• Private parties will rarely be deemed state actors absent detailed conspiracy or joint-action allegations.

This ruling will guide trial courts in screening meritless suits, resolving jurisdictional questions, and applying immunity doctrines in future civil rights litigation.