Clarifying the Scope of Rooker–Feldman and Younger Abstention in Federal Review of Domestic Relations Cases

Introduction

Covington v. Humphries, decided May 19, 2025 by the Tenth Circuit, is a landmark decision refining two key federal-jurisdiction doctrines—Rooker–Feldman and Younger abstention—when applied to federal lawsuits challenging ongoing state domestic relations proceedings. The dispute arose from over a decade of Colorado state–court litigation between Elizabeth Covington (“Ms. Covington”) and John Humphries (“Mr. Humphries”) over child custody, allegations of child abuse, and the actions of state social‐service actors (Jill Betz and Carol Friedrich) and a court‐appointed child representative (James Plumhoff). In March 2023, Ms. Covington and her son J.M.H. filed § 1981 and § 1983 claims in federal district court against these parties. The district court dismissed for lack of subject–matter jurisdiction under Rooker–Feldman and, alternatively, Younger abstention. On appeal, the Tenth Circuit reversed, holding that (1) Rooker–Feldman applies only when the state judgment is final at the time the federal suit is filed, and (2) Younger abstention must be confined to the three “exceptional” categories identified in Sprint Communications, Inc. v. Jacobs, none of which include ordinary domestic relations proceedings.

Summary of the Judgment

The Tenth Circuit unanimously held:

Rooker–Feldman inapplicable: Because the state court’s July 2022 custody order was on appeal when the federal complaint was filed, it was not “final” under controlling precedents (Guttman v. Khalsa, D.A. Osguthorpe Fam. P’ship v. ASC Utah). The federal district court therefore had jurisdiction to consider § 1983 damages claims.
Younger abstention inapplicable: The ongoing domestic relations case does not fall within any of the three limited categories that warrant Younger abstention—criminal prosecutions, “civil enforcement” actions akin to criminal prosecutions, or state contempt/enforcement processes essential to the state judicial system (Sprint Communications, New Orleans Pub. Serv., Juidice, Pennzoil). Domestic relations custody disputes lie outside these “exceptional” categories.
Remand: The case is returned to the district court for merits‐stage proceedings on the § 1981 and § 1983 claims.

Analysis

1. Precedents Cited

Rooker v. Fidelity Trust Co. (263 U.S. 413 (1923)) and District of Columbia Court of Appeals v. Feldman (460 U.S. 462 (1983)) – the foundational cases barring federal review of final state‐court judgments.
Guttman v. Khalsa (446 F.3d 1027) – confirmed Rooker–Feldman applies only when state proceedings are final at filing.
D.A. Osguthorpe Fam. P’ship v. ASC Utah (705 F.3d 1223) and Bear v. Patton (451 F.3d 639) – reaffirmed the finality inquiry for Rooker–Feldman in the Tenth Circuit.
Younger v. Harris (401 U.S. 37 (1971)) – established abstention from interference in certain ongoing state proceedings.
New Orleans Public Service, Inc. v. Council (491 U.S. 350) – categorized the types of state proceedings that trigger Younger.
Sprint Communications, Inc. v. Jacobs (571 U.S. 69) – sharply limited Younger abstention to three “exceptional” categories: criminal, certain civil‐enforcement, and contempt/enforcement processes.
Supporting Tenth Circuit cases on abstention and federal jurisdiction (e.g., In re Miller, Miller v. Deutsche Bank; Brown ex rel. Brown v. Day; Graff v. Aberdeen Enterprises).

2. Legal Reasoning

a. Rooker–Feldman Finality Requirement
The court applied the bedrock principle that Rooker–Feldman prohibits federal district courts from acting as appellate tribunals over final state judgments. Because Ms. Covington’s federal suit was filed while the Colorado appellate process was still underway (appeal of the July 2022 order), the state judgment lacked finality and Rooker–Feldman posed no bar. The panel relied on Guttman’s holding that pendency of a state‐court appeal or certiorari petition means the state judgment is not final.

b. Younger’s Limited Scope Post-Sprint
The court stressed that Sprint Communications confined Younger abstention to three narrow categories. It methodically considered each:

Criminal prosecutions: plainly inapplicable.
Civil‐enforcement akin to criminal: requires a state‐actor plaintiff, sanctioning posture, and punitive character (e.g., child‐abuse enforcement by state agencies in Moore v. Sims). Here, the domestic relations case was a private custody dispute initiated by Ms. Covington, not a sanction or enforcement action by the state.
Contempt/enforcement of judgments: concerns processes integral to upholding state‐court orders (Juidice, Pennzoil). A custody allocation order does not itself implicate the state’s contempt machinery or its sovereign interest in enforcing judicial processes.

Because none of the “exceptional” categories applied, Younger abstention was unavailable.

3. Impact

Covington v. Humphries carries significant consequences for federal civil rights litigation arising out of active state‐court family law or domestic relations proceedings:

Federal courts retain jurisdiction to hear § 1983 and related damages actions when state proceedings are not yet final, ensuring federal remedies against alleged constitutional violations by state actors are not postponed indefinitely.
Younger abstention cannot be invoked simply because a domestic relations case is ongoing; litigants may pursue federal civil rights claims without automatic deference to state‐court custody disputes.
The decision reinforces strict adherence to the Sprint categories, discouraging lower courts from expanding Younger into “run‐of‐the‐mill” civil contests.
Practitioners should carefully track the finality of state judgments and the nature of state proceedings when evaluating jurisdiction and abstention risks in parallel federal suits.

Complex Concepts Simplified

Rooker–Feldman doctrine: A federal court cannot function as an appeals court over a state‐court decision once that decision is final. If the state case is still in progress or under appeal, the federal court may proceed.
Younger abstention: Normally, federal courts must not interfere with ongoing state processes that fall into three special categories: (1) criminal prosecutions, (2) civil‐enforcement actions by the state akin to criminal cases, or (3) contempt or enforcement proceedings that keep state judgments effective. Family law and custody disputes generally do not qualify.
Finality: A state judgment is “final” when all appeals and certiorari avenues are exhausted or lapsed. Pending appeals mean the judgment is not yet final for Rooker–Feldman purposes.

Conclusion

Covington v. Humphries clarifies two fundamental jurisdictional doctrines at the intersection of federal civil rights and state domestic relations law. By reaffirming that Rooker–Feldman applies only to fully concluded state judgments and strictly limiting Younger abstention to the three “exceptional” categories outlined in Sprint, the Tenth Circuit has strengthened federal oversight of alleged constitutional violations by state‐court actors—even in the emotionally charged context of child‐custody and family disputes. Lower courts and practitioners must now apply these doctrines with precision, ensuring neither premature abstention nor unjustified dismissal impedes vindication of federal rights.