Jurisdictional Dismissals Under Rooker-Feldman/Younger Must Be Without Prejudice (and Undeveloped Appellate Arguments Are Waived)

1. Introduction

In Woodham v. HireRight, LLC (10th Cir. Feb. 13, 2026) (unpublished “Order and Judgment”), pro se plaintiff Robert Evan Woodham sued a wide range of defendants—private companies (HireRight, Uber, Amazon), individual lawyers, Utah and Arizona municipalities, and state-court judges—alleging violations of the Fair Credit Reporting Act (FCRA), the Americans with Disabilities Act (ADA), and the Fourteenth Amendment’s Due Process Clause (asserted through 42 U.S.C. § 1983).

The case arose from three clusters of events: (1) employment-related disputes (background check and termination issues with Uber and Amazon), (2) Utah traffic/licensure enforcement and resulting state proceedings, and (3) protective-order litigation in Utah and Arizona.

The district court, after screening, dismissed the complaint under Rule 12(b)(1) (lack of subject-matter jurisdiction), Rule 12(b)(6) (failure to state a claim), and 28 U.S.C. § 1915(e) (frivolousness in in forma pauperis proceedings). On appeal, the Tenth Circuit largely affirmed, but vacated in part to ensure the jurisdictional dismissals were entered without prejudice.

2. Summary of the Opinion

The Tenth Circuit held:

  • Jurisdiction (Rule 12(b)(1)): To the extent Woodham’s due process claims effectively sought federal review and rejection of adverse state-court outcomes, they were barred by Rooker-Feldman and/or warranted abstention under Younger.
  • Waiver: Woodham did not meaningfully address Younger abstention or the district court’s § 1915 frivolousness ruling on appeal; those issues were treated as waived.
  • Pleading (Rule 12(b)(6)): The remaining claims were inadequately pleaded; conclusory accusations did not meet the plausibility standard.
  • Form of dismissal: Because Rooker-Feldman/Younger dismissals are jurisdictional, the panel vacated the judgment only as to those claims and remanded with instructions to dismiss them without prejudice.
  • Conduct admonition: The panel admonished Woodham for abusive rhetoric directed at the district judge and staff.

3. Analysis

A. Precedents Cited

1) Standards for extracting facts and pro se treatment

  • Crown Point I, LLC v. Intermountain Rural Elec. Ass'n, 319 F.3d 1211 (10th Cir. 2003): Cited for the routine rule that, on review of dismissal, facts are drawn from the complaint’s allegations and viewed in the plaintiff’s favor.
  • Mann v. Boatright, 477 F.3d 1140 (10th Cir. 2007) and Hall v. Bellmon, 935 F.2d 1106 (10th Cir. 1991): Used to frame the balance between liberal construction for pro se litigants and the prohibition against the court acting as a litigant’s advocate.
  • West-Helmle v. Denver District Attorney's Office, 2025 WL 2317368 (10th Cir. Aug. 12, 2025) (unpublished): Cited both to justify affording some liberality to a legally trained but unlicensed pro se litigant and, later, to underscore that pro se status is not a license for abusive filings.

2) Appellate and dismissal standards (12(b)(1), 12(b)(6), and § 1915)

  • Hunt v. Uphoff, 199 F.3d 1220 (10th Cir. 1999) and Perkins v. Kansas Dept. of Corrections, 165 F.3d 803 (10th Cir. 1999): Provide the general de novo framework and “accept allegations as true” approach for dismissal review.
  • Denton v. Hernandez, 504 U.S. 25 (1992) and Neitzke v. Williams, 490 U.S. 319 (1989): Supply the definition and review standard for § 1915 frivolousness (abuse of discretion; “arguable basis” in law or fact; courts may dismiss “fantastic or delusional” factual scenarios).
  • United States v. McComb, 519 F.3d 1049 (10th Cir. 2007): Defines abuse of discretion as resting on erroneous legal conclusions or clearly erroneous factual findings.
  • Ashcroft v. Iqbal, 556 U.S. 662 (2009): Anchors the panel’s conclusion that Woodham’s allegations were too conclusory—mere “the-defendant-unlawfully-harmed-me” accusations are insufficient.
  • AlexSam, Inc. v. Aetna, Inc., 119 F.4th 27 (Fed. Cir. 2024): Cited for the principle that plausibility cannot be bolstered by a judge’s assessment of a plaintiff’s credibility; pleading sufficiency turns on allegations, not perceived trustworthiness or experience.

3) Rooker-Feldman, Younger, and jurisdictional consequences

  • Johnson v. De Grandy, 512 U.S. 997 (1994): Quoted for the core formulation of Rooker-Feldman—federal district courts cannot provide what is essentially appellate review of state-court judgments.
  • Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280 (2005): Supports the “review and reject” test; if the federal claim’s success requires rejecting the state judgment, Rooker-Feldman is implicated.
  • PJ ex rel. Jensen v. Wagner, 603 F.3d 1182 (10th Cir. 2010): Used to rebut Woodham’s assertion that § 1983 claims cannot trigger Rooker-Feldman; the panel notes § 1983 suits can be barred when they functionally attack state judgments.
  • D.L. v. Unified School District No. 497, 392 F.3d 1223 (10th Cir. 2004): Defines Younger abstention, emphasizing federal noninterference with ongoing state proceedings implicating important state interests.
  • United States v. Walker, 918 F.3d 1134 (10th Cir. 2019): Provides the waiver principle—issues not adequately raised are deemed waived.
  • Graff v. Aberdeen Enterprizes, II, Inc., 65 F.4th 500 (10th Cir. 2023): Cited for the proposition that Rooker-Feldman is a jurisdictional limit.
  • Brereton v. Bountiful City Corp., 434 F.3d 1213 (10th Cir. 2006): Critical to the remedy—dismissals for lack of jurisdiction ordinarily must be without prejudice.
  • McAuliffe v. Vail Corporation, 69 F.4th 1130 (10th Cir. 2023): Applied as a template for vacating and remanding to modify a jurisdictional dismissal to be without prejudice.
  • Heck v. Humphrey, 512 U.S. 477 (1994): Not decided, but flagged as a potential additional barrier to claims that would imply invalidity of an outstanding conviction.

4) Litigation conduct and judicial integrity

  • Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836 (10th Cir. 2005): Supports the panel’s admonition that filings attempting to impugn judicial integrity without basis are intolerable.

5) State case as background

  • Park City Municipal Corporation v. Woodham, 545 P.3d 221 (Utah 2024): Not used as a legal standard, but important factual context—Woodham’s state traffic conviction had already been affirmed by Utah’s highest court, strengthening the inference that his federal claims sought to relitigate or undermine state adjudications.

B. Legal Reasoning

1) The court separated the complaint into functional “clusters”

A key methodological move was the panel’s organization of Woodham’s pleadings into three factual categories (employment, traffic/licensure, and family/protective-order disputes). That categorization mattered because the jurisdictional doctrines (Rooker-Feldman/Younger) primarily attached to claims tethered to state proceedings (traffic and protective-order litigation), while Rule 12(b)(6) and § 1915 applied across the remainder.

2) Rooker-Feldman applied where federal relief required rejecting state judgments

Invoking Johnson v. De Grandy and Exxon Mobil Corp. v. Saudi Basic Industries Corp., the panel treated Woodham’s due process claims as impermissible de facto appeals—claims inviting the federal court to “review and reject” adverse state-court results. The panel rejected Woodham’s attempt to avoid Rooker-Feldman by labeling his claims “misconduct” under § 1983, noting via PJ ex rel. Jensen v. Wagner that § 1983 suits often implicate Rooker-Feldman when they seek to undo state outcomes.

3) Younger abstention was an independent jurisdictional barrier—and was waived on appeal

The district court had also relied on Younger abstention as explained in D.L. v. Unified School District No. 497. On appeal, Woodham “never once addresses Younger,” so the panel deemed the argument waived under United States v. Walker. Even with waiver, the panel reiterated Younger’s jurisdictional character (citing D.L.), reinforcing the district court’s screening posture in cases that would interfere with ongoing state processes.

4) The panel corrected the form of the jurisdictional dismissal: without prejudice

The opinion’s most concrete doctrinal “rule” is remedial: because Rooker-Feldman/Younger limits are jurisdictional (citing Graff v. Aberdeen Enterprizes, II, Inc. and D.L.), dismissal must ordinarily be without prejudice. Relying on Brereton v. Bountiful City Corp., and following McAuliffe v. Vail Corporation, the panel vacated the judgment only as to those claims and remanded for modification to “without prejudice.” This preserves the formal principle that a court lacking jurisdiction cannot enter a merits-preclusive judgment.

5) Rule 12(b)(6): conclusory pleading and the irrelevance of “legal experience”

For the claims not jurisdictionally barred, the panel affirmed dismissal for failure to state a claim. The court emphasized that Woodham’s allegations did not rise above conclusory assertions prohibited by Ashcroft v. Iqbal. The panel also rejected Woodham’s suggestion that his prior legal experience should bolster plausibility; citing AlexSam, Inc. v. Aetna, Inc., it underscored that plausibility cannot be built on judicial credibility assessments.

6) § 1915 frivolousness: affirmed by waiver

Although the district court dismissed as frivolous under § 1915 (guided by Neitzke v. Williams and Denton v. Hernandez), Woodham did not address frivolousness on appeal. Under United States v. Walker, the panel treated the issue as waived and affirmed the § 1915 dismissal for the non-jurisdictionally barred claims.

7) Judicial process protection: admonition for abusive filings

The panel’s concluding section draws from Garrett v. Selby Connor Maddux & Janer (and West-Helmle v. Denver District Attorney's Office) to police appellate decorum. The court framed abusive accusations against the district judge and staff as “intolerable,” warning that pro se practice is a shield against technical traps, not a weapon for insults.

C. Impact

1) Practical rule for district courts: jurisdictional dismissals must be non-prejudicial

Even though this disposition is nonprecedential, it reinforces a recurring, consequential housekeeping principle: when a district court dismisses under Rooker-Feldman or Younger, it should clearly specify dismissal without prejudice. The remand here functions as a cautionary template: if the judgment is silent or ambiguous, an appellate panel may vacate in part to correct the form of judgment.

2) Appellate practice: undeveloped arguments (and ignored grounds) lose

The case is also a reminder that appellants must engage each independent basis for dismissal. By failing to address Younger and § 1915, Woodham effectively ensured affirmance on those grounds, irrespective of any debate about other issues.

3) Screening and pleading discipline in multi-defendant, multi-theory complaints

The opinion reflects a broader trend in federal pleading practice: sprawling complaints spanning multiple events, defendants, and legal theories are vulnerable to early dismissal when they do not provide concrete, defendant-specific factual allegations establishing each element of each claim.

4) Conduct deterrence

The admonition portion signals that the Tenth Circuit may respond sharply to ad hominem attacks in filings, potentially affecting how litigants frame arguments and how courts manage abusive submissions.

4. Complex Concepts Simplified

  • Rule 12(b)(1) (subject-matter jurisdiction): The court must dismiss if it lacks power to decide the case at all. If dismissed for lack of jurisdiction, the court is not deciding who is right—only that the forum is improper.
  • Rooker-Feldman doctrine: Federal district courts cannot act like appellate courts reviewing state-court judgments. If the federal claim would succeed only by concluding the state court was wrong, it is typically barred.
  • Younger abstention: Even if a federal court has jurisdiction, it sometimes must step back to avoid interfering with ongoing state proceedings (often criminal or quasi-criminal matters) that implicate important state interests.
  • Dismissal “without prejudice” vs. “with prejudice”: Without prejudice means the claim is not finally adjudicated on the merits (and may be refiled if a proper jurisdictional posture later exists). With prejudice is a merits-ending judgment with claim-preclusive consequences.
  • Rule 12(b)(6) (failure to state a claim): Even assuming the facts alleged are true, the complaint must plausibly show entitlement to relief; labels and conclusions are not enough.
  • 28 U.S.C. § 1915(e) frivolousness: In in forma pauperis cases, courts may dismiss claims that have no arguable legal basis or are factually “clearly baseless.”
  • Waiver on appeal: If an appellant does not argue an issue, the appellate court generally treats it as forfeited/waived and will not consider it.

5. Conclusion

Woodham v. HireRight, LLC primarily matters for its procedural clarifications rather than for any new substantive interpretation of the FCRA, ADA, or due process. The Tenth Circuit reaffirmed that claims functioning as challenges to state-court outcomes are jurisdictionally barred (Rooker-Feldman) or require abstention (Younger), and that such jurisdictional dismissals must be entered without prejudice. The decision also underscores two practical lessons: (1) pleadings must contain concrete, defendant-specific facts meeting the plausibility standard of Ashcroft v. Iqbal, and (2) appellate courts will affirm when appellants fail to address independent grounds for dismissal. Finally, the court’s admonition reinforces that vigorous advocacy does not permit abusive attacks on judicial officers or staff.