Bellinsky v. Galan: Tenth Circuit Reaffirms “Sprint Gatekeeping” for Younger Abstention and Tightens Rooker-Feldman in Domestic-Relations Civil-Rights Suits

1. Introduction

Bellinsky v. Galan, United States Court of Appeals for the Tenth Circuit, decided 22 July 2025, arose from two civil-rights actions filed by Rabbi Jacob Bellinsky against his former spouse, her counsel, several Colorado judges, clerks, prosecutors, and the State of Colorado. Rabbi Bellinsky alleged a broad conspiracy that deprived him of custodial rights and liberty through misuse of state family-law and criminal processes. The district court dismissed both actions, principally invoking Younger v. Harris abstention and the Rooker-Feldman doctrine, and denied Bellinsky’s motions for discovery and judicial recusal. On appeal, the Tenth Circuit reversed, clarifying important limitations on the abstention doctrines and providing guidance on state representation and judicial recusal in §1983/§1985 litigation that overlays state domestic-relations proceedings.

2. Summary of the Judgment

Recusal: The appellate court upheld the denial of Bellinsky’s recusal motions, holding no reasonable, objective basis existed to question the impartiality of either the magistrate or district judge.
State Attorney General Representation: The court affirmed that, under Colo. Rev. Stat. § 24-31-101(1)(e)/(m), the Attorney General may represent state employees sued in their individual capacities for conduct arising from official duties.
Younger Abstention: The panel reversed the district court’s blanket abstention. After Sprint Communications, Inc. v. Jacobs, a federal court must first verify that the underlying state proceeding falls within one of three “Sprint categories” before applying the Middlesex factors. The district court skipped that step.
Rooker-Feldman: Because no final, adverse state judgment existed when Bellinsky sued, and he sought only damages (not modification or nullification of state judgments), Rooker-Feldman did not divest jurisdiction.
Disposition: Both district-court dismissals were vacated; the cases were remanded for further proceedings. Bellinsky’s IFP motions were granted; other appellate motions denied.

3. Analysis

3.1 Precedents Cited and Their Influence

Younger v. Harris, 401 U.S. 37 (1971) – foundational abstention doctrine to avoid interference with ongoing state proceedings.
Sprint Communications, Inc. v. Jacobs, 571 U.S. 69 (2013) – sharply limited Younger to three enumerated categories (criminal, quasi-criminal civil enforcement, and civil proceedings that further state courts’ judicial functions).
Middlesex County Ethics Committee v. Garden State Bar Ass’n, 457 U.S. 423 (1982) – three-factor test applied only if the proceeding fits a Sprint category.
New Orleans Public Service, Inc. (NOPSI) v. Council of New Orleans, 491 U.S. 350 (1989) – early identification of “judicial-function” proceedings.
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) & Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) – basis of jurisdictional bar on federal review of state judgments.
In re Miller, 666 F.3d 1255 (10th Cir. 2012) – modern articulation of Rooker-Feldman.
Travelers Casualty Insurance Co. v. A-Quality Auto Sales, 98 F.4th 1307 (10th Cir. 2024) – restates “Sprint-first” sequencing.
Liteky v. United States, 510 U.S. 540 (1994) – adverse rulings seldom justify recusal.
Barnett v. Hall, Estill, Hardwick, Gable, Golden & Nelson, P.C., 956 F.3d 1228 (10th Cir. 2020) – objective standard for recusal.

Collectively, these precedents shaped the panel’s conclusion that the district court had misapplied Younger and Rooker-Feldman. The court also distinguished its own unpublished decision in Morkel v. Davis, 513 F. App’x 724 (10th Cir. 2013), explaining that Sprint—decided later—overrides any broader reading of Younger in custody disputes.

3.2 Legal Reasoning in Depth

Step-Zero – Sprint Gatekeeping.
The court emphasized that Sprint created a “gate.” Only if the state proceeding fits one of three categories do federal courts move to the Middlesex comforts (ongoing proceeding, important interest, adequate forum). Domestic relations matters—including routine custody modifications—do not automatically qualify. The district court overlooked this threshold question, leading to reversible error.
Misapplication of Rooker-Feldman.
The panel reiterated that Rooker-Feldman is triggered only when: (1) the plaintiff lost in state court, (2) the judgment is final, and (3) the federal claim seeks review or rejection of that judgment. Rabbi Bellinsky sued before the domestic and one criminal case concluded, and the other criminal case had been dismissed in his favor. He sought damages for an alleged conspiracy, not an alteration of state decrees. Thus, federal jurisdiction remained intact.
Judicial Recusal Standard.
Applying 28 U.S.C. § 455 and Liteky, the court held that dissatisfaction with rulings or speculative allegations of bias do not meet the “reasonable person, fully informed” test.
State Representation of Officials.
The Attorney General’s statutory duty to defend officials (Colo. Rev. Stat. § 24-31-101) encompasses suits seeking personal-capacity damages if conduct stems from official acts. The panel read the statute broadly to advance efficient defense of state interests and employees.

3.3 Impact on Future Litigation and the Law

Domestic-Relations Civil-Rights Claims: Plaintiffs alleging constitutional violations connected to custody or protection-order proceedings retain a federal forum unless the state proceeding is (a) quasi-criminal (e.g., contempt) or (b) injunction enforcement directly implicating court orders. Routine parenting-time disputes no longer suffice for abstention.
District-Court Protocol: Judges must articulate a Sprint analysis on the record before invoking Younger. Failure to do so risks reversal.
Narrow Scope of Rooker-Feldman: The decision continues a national trend (7th & 8th Circuits cited) confining the doctrine to direct attacks on finalized judgments, thereby lowering jurisdictional hurdles for damages-only civil-rights suits.
State AG Defense: Confirms that state attorneys general may defend judges, clerks, and prosecutors sued individually, reinforcing the practical unity of sovereign and officer in §1983 contexts.
Recusal Clarification: Strengthens the “adverse rulings ≠ bias” principle, discouraging tactical disqualification motions.

4. Complex Concepts Simplified

Younger Abstention: A rule telling federal courts “stay out” when a state court is already handling certain kinds of cases. After Sprint, those kinds are limited to: (1) criminal prosecutions; (2) similar civil enforcement (e.g., a state agency fining you); (3) court-order enforcement (e.g., contempt). Child-custody litigation is not automatically in the club.
Sprint Gatekeeping: Think of Sprint as a bouncer; only if your state case is on the VIP list (three categories) can Younger be discussed further.
Rooker-Feldman Doctrine: Federal trial courts cannot function as appellate courts over state decisions. If you simply want money for a wrong, and you’re not asking the federal court to undo a state judgment, you are usually safe from this doctrine.
Recusal Standard (“Reasonable Person Test”): It’s not enough that you think a judge is biased. Would an informed bystander think so? If not, recusal fails.

5. Conclusion

Bellinsky v. Galan cements two vital propositions within the Tenth Circuit: (1) Sprint is the indispensable first step in any Younger analysis; domestic-relations proceedings warrant abstention only if they fall within the Sprint taxonomy; and (2) Rooker-Feldman remains a narrow, judgment-focused bar; damages-only claims that do not seek to overturn a state decree survive. The ruling realigns district-court practice with Supreme Court precedent, guaranteeing that litigants alleging constitutional misconduct in family-law settings receive a fair federal hearing. By clarifying representation and recusal issues, the decision offers a procedural roadmap for future civil-rights litigants and courts alike.