Third Circuit: Even Where Rooker-Feldman/Younger May Not Dispose of a § 1983 Challenge to Family-Court Conduct, Immunities and § 1983 Merits Defects Require Dismissal—and Official-Capacity Sovereign-Immunity Dismissals Must Be Without Prejudice

1. Introduction

Kason Jamison, proceeding pro se, filed a federal civil-rights action under 42 U.S.C. § 1983 in the District of New Jersey against (1) New Jersey Superior Court Judge Michelle Perry-Thompson (in both individual and official capacities) and (2) his child’s mother, Chrislyn Morgan. Jamison alleged constitutional violations tied to New Jersey state child-support and custody proceedings and sought damages along with declaratory and injunctive relief.

The district court screened the complaint under 28 U.S.C. § 1915(e)(2)(B) (in forma pauperis screening), emphasized Jamison’s prior federal attempts to challenge child-support obligations, and dismissed the action. It relied principally on Younger abstention (for ongoing state proceedings) and the Rooker-Feldman doctrine (for already-entered state orders), and found amendment futile.

On appeal, Jamison argued the case should proceed because he purportedly did not seek appellate-type review of state-court rulings; he framed at least one contention—state actors “repeatedly refused to enforce a valid state court order granting him the right to obtain a passport”—as an “independent” constitutional claim.

2. Summary of the Opinion

The Third Circuit affirmed the dismissal, but on a merits-and-immunity analysis that rendered the case untenable even if one assumes Jamison’s “passport” theory could qualify as an “independent” claim not barred by Rooker-Feldman.

Specifically, the panel held:

• No § 1983 claim lay against the child’s mother because she is a private actor and the complaint did not plausibly allege state action.
• Judicial immunity barred individual-capacity damages claims against Judge Perry-Thompson based on her conduct in a child-support hearing; and declaratory/injunctive relief against the judge was improper where she acted adjudicatively.
• Sovereign immunity deprived the federal courts of jurisdiction over official-capacity damages claims and barred retrospective declaratory and injunctive relief; further, requested injunctions interfering with state proceedings ran into the Anti-Injunction Act.
• Because sovereign-immunity dismissals should be without prejudice, the court modified the judgment to reflect that official-capacity claims for damages and retrospective declaratory/injunctive relief were dismissed without prejudice.

3. Analysis

3.1 Precedents Cited (and how they shaped the outcome)

The opinion is notable less for resolving Rooker-Feldman/Younger at length and more for using those doctrines as a backdrop while pivoting to threshold § 1983 defects and immunity barriers.

A. Appellate review standards and issue forfeiture

• In re Wettach, 811 F.3d 99, 115 (3d Cir. 2016): The panel invoked Wettach twice for forfeiture principles—(i) Jamison forfeited challenges to dismissal of state-law claims by not developing them in his opening brief; and (ii) he likewise did not challenge denial of his motion for an extension of time to appeal. This reflects a recurring appellate gatekeeping rule: even pro se litigants must meaningfully brief issues to preserve them.
• In re Adams, 151 F.4th 144, 150 (3d Cir. 2025) and Borowski v. Kean Univ., 68 F.4th 844, 846 (3d Cir. 2023): Cited for de novo review standards for Rooker-Feldman and Younger, respectively—signaling that while those doctrines are often dispositive, the court remained free to affirm on other grounds.
• Murray v. Bledsoe, 650 F.3d 246, 247 (3d Cir. 2011) (per curiam): Provided the doctrinal permission to “affirm on any basis supported by the record,” enabling the panel to uphold dismissal even if Jamison could evade Rooker-Feldman/Younger as to a subset of allegations.

B. “Independent claims” and the Rooker-Feldman boundary

• Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159, 167-69 (3d Cir. 2010): The panel used Great W. Mining as the key Third Circuit articulation that not all claims touching state-court litigation are barred; “independent” claims alleging separate constitutional injuries can fall outside Rooker-Feldman. Here, the court assumed arguendo that the “passport-order enforcement” allegation might be such an independent claim, but still found the complaint “plainly defective on the merits.”
• Butcher v. Wendt, 975 F.3d 236, 244 (2d Cir. 2020), Jordon v. Att'y Gen., 424 F.3d 320, 325 n.8 (3d Cir. 2005), and Steel Co. v. Citizens for a Better Environment, 523 U.S. 83, 93-94 (1998): In a footnote, the panel explained it could assume “hypothetical statutory jurisdiction” because Rooker-Feldman does not implicate Article III jurisdiction. This matters: it legitimizes a common appellate move—resolving a case on clearer merits/immunity grounds without definitively parsing statutory-jurisdiction doctrines, so long as Article III jurisdiction is secure.

C. § 1983 “state action” and private defendants

• Benn v. Universal Health Sys., Inc., 371 F.3d 165, 169-71 (3d Cir. 2004): Supported the foundational rule that § 1983 reaches only conduct “under color of state law,” generally excluding purely private actors.
• Lindke v. Freed, 601 U.S. 187, 195-96 (2024): Cited for the plausibility/standards for attributing conduct to the state. The panel found Jamison alleged no facts suggesting the child’s mother acted under color of state law.

D. Judicial immunity and limits on equitable relief against judges

• Mireles v. Waco, 502 U.S. 9, 11-12 (1991) (per curiam): Controlled the damages analysis against Judge Perry-Thompson individually. Because the alleged acts (hearing management, credibility assessments, rulings/refusals to rule) were quintessentially judicial and not alleged to be taken in the complete absence of jurisdiction, absolute judicial immunity applied.
• Allen v. DeBello, 861 F.3d 433, 439-42 (3d Cir. 2017): Guided the panel’s rejection of Jamison’s requests for declaratory and injunctive relief against the judge where the judge acted in an adjudicatory capacity—reflecting the judiciary’s strong protection from being made a defendant for case-handling decisions via § 1983.

E. Sovereign immunity, Ex parte Young limits, and the Anti-Injunction Act

• Benn v. First Jud. Dist. of Pa., 426 F.3d 233, 238-39 (3d Cir. 2005) and Chisolm v. McManimon, 275 F.3d 315, 323 (3d Cir. 2001): Supported the holding that sovereign immunity deprives federal courts of subject matter jurisdiction over official-capacity damages claims against state judicial officers (i.e., suits effectively against the State).
• Merritts v. Richards, 62 F.4th 764, 771-72 (3d Cir. 2023): Did two crucial jobs: (i) it supplied the “prospective relief” requirement for fitting within the Ex parte Young exception, and (ii) it supported the remedy correction—dismissals based on sovereign immunity should be without prejudice.
• Collins v. Daniels, 916 F.3d 1302, 1316 (10th Cir. 2019): Reinforced that Ex parte Young cannot be used simply to obtain a declaration that state officers violated federal rights in the past; Jamison’s requested declarations about Judge Perry-Thompson’s past unlawfulness were not “properly characterized as prospective.”
• In re Prudential Ins. Co. of Am. Sales Prac. Litig., 261 F.3d 355, 364 (3d Cir. 2001): Grounded the Anti-Injunction Act barrier to federal injunctions that would interfere with state proceedings (here, attempts to enjoin future child support enforcement and custody proceedings).

3.2 Legal Reasoning (how the court reached the result)

The panel’s logic followed a layered “even if” structure that is common in civil-rights appeals arising from state domestic-relations litigation:

1. Assume away the hardest jurisdictional label: Rather than definitively classify the “passport order” contention under Rooker-Feldman, the court assumed it might be “independent” under Great W. Mining & Mineral Co. v. Fox Rothschild LLP.
2. Dispose of private-party claims at the state-action threshold: Under § 1983, the child’s mother could not be liable absent plausible allegations of acting “under color of state law,” which were missing under Benn v. Universal Health Sys., Inc. and Lindke v. Freed.
3. Apply absolute judicial immunity to adjudicatory acts: The judge’s challenged conduct—denying remote attendance, declining to adjudicate certain issues, making credibility assessments—fell squarely within the judicial function protected by Mireles v. Waco.
4. Block end-runs via equitable remedies against judges: The court treated Jamison’s declaratory/injunctive requests against the judge as improper where the judge acted adjudicatively, consistent with Allen v. DeBello.
5. Enforce sovereign immunity for official-capacity claims: Official-capacity damages claims were jurisdictionally barred under Benn v. First Jud. Dist. of Pa. and Chisolm v. McManimon. Retrospective declarations and injunctions were likewise barred because they were not genuinely prospective under Merritts v. Richards (and consistent with Collins v. Daniels).
6. Respect the Anti-Injunction Act: To the extent Jamison sought to restrain future child-support/custody enforcement proceedings, In re Prudential Ins. Co. of Am. Sales Prac. Litig. foreclosed such relief.
7. Correct the judgment’s prejudice designation: Because sovereign immunity is jurisdictional, the panel modified the judgment so the relevant official-capacity claims are dismissed without prejudice, per Merritts v. Richards.

3.3 Impact (practical effects on future litigation)

• Family-court-related § 1983 suits remain difficult to plead and maintain: The opinion illustrates that even when a plaintiff tries to reframe a domestic-relations grievance as an “independent” federal claim, immunities (judicial and sovereign) and the state-action requirement often defeat the case before discovery.
• Courts may bypass contested statutory-jurisdiction doctrines when merits/immunity is clearer: The panel’s willingness to assume away Rooker-Feldman for argument’s sake underscores a litigation reality: if a complaint is plainly defective for other reasons, appellate courts may affirm without definitively resolving the Rooker-Feldman/Younger boundary fight.
• Remedial precision matters—“without prejudice” for sovereign-immunity dismissals: The modification reinforces a key procedural consequence: jurisdictional dismissals do not adjudicate the merits and therefore must be without prejudice—an important point for claim preclusion and for any later attempt to pursue a properly structured prospective-relief claim (if one could be stated).
• Anti-Injunction Act remains a powerful backstop: Even where plaintiffs seek “forward-looking” relief, injunctions that would intrude on state enforcement proceedings face an additional federal statutory barrier.

4. Complex Concepts Simplified

• 28 U.S.C. § 1915(e)(2)(B) screening: When a plaintiff proceeds in forma pauperis, the court must dismiss complaints that are frivolous, fail to state a claim, or seek relief from immune defendants—often before the defendants are served.
• Rooker-Feldman doctrine: Federal district courts cannot function as appellate courts to review or overturn state-court judgments. A claim is sometimes permissible if it alleges an “independent” federal injury rather than asking the federal court to reject the state judgment.
• Younger abstention: Federal courts often refrain from interfering with certain ongoing state proceedings (especially where important state interests are involved and the state forum can hear federal issues).
• “Under color of state law” (state action): § 1983 applies to government actors (and, in limited circumstances, private persons who can be treated as state actors). Simply being involved in litigation with the state, or benefitting from state-court orders, does not automatically make a private person a state actor.
• Judicial immunity: Judges are absolutely immune from damages for acts performed in their judicial role, unless they act in a complete absence of jurisdiction or perform nonjudicial acts.
• Sovereign immunity and Ex parte Young: States (and state officials sued in official capacity) are generally immune from damages in federal court. A narrow exception allows suits for genuinely prospective relief to stop an ongoing violation of federal law—but not to declare past conduct unlawful or to remedy past harms.
• Anti-Injunction Act: A federal court generally cannot enjoin state-court proceedings, subject to narrow exceptions; this limits federal injunctive relief aimed at stopping state enforcement actions.
• Dismissal “without prejudice”: The claim is dismissed without a merits determination; the plaintiff is not barred (by that judgment alone) from attempting to refile a jurisdictionally proper claim.

5. Conclusion

Jamison reinforces a durable set of constraints on federal civil-rights suits that attempt to repackage grievances from child-support and custody litigation. Even when a plaintiff frames allegations as “independent” constitutional wrongs outside Rooker-Feldman and tries to avoid Younger concerns, the suit may still fail at the threshold due to (1) the absence of state action for private defendants, (2) judicial immunity for adjudicatory conduct, (3) sovereign immunity for official-capacity claims and retrospective relief, and (4) the Anti-Injunction Act for efforts to stop future state proceedings. The opinion’s key doctrinal housekeeping is its modification clarifying that sovereign-immunity dismissals must be entered without prejudice.