Title II ADA Injunctions Require Plausible Future Harm; Federal Courts Lack Jurisdiction to Rework State Child-Support Enforcement—Dismissals Must Be Without Prejudice

1. Introduction

This appeal arose from Kevin B. Glasco’s pro se federal lawsuit challenging (1) alleged disability-based failures to accommodate him in Jefferson County Family Court child-support proceedings under Title II of the Americans with Disabilities Act (“ADA”), and (2) alleged civil-rights violations tied to Alabama’s child-support collection practices—particularly garnishment of Social Security disability income and alleged failures to credit auxiliary Social Security Administration (“SSA”) payments.

The defendants were the Alabama Department of Human Resources (“ADHR”) and the Jefferson County Family Court. The district court dismissed the amended complaint sua sponte under the in forma pauperis screening statute, 28 U.S.C. § 1915(e)(2)(B). On appeal, Glasco argued that the district court failed to adjudicate his ADA and civil-rights claims on the merits and abused its discretion by not ruling on requested emergency injunctive and sealing relief.

The Eleventh Circuit’s decision is noteworthy less for resolving the substantive ADA or child-support questions than for sharpening two gatekeeping constraints that routinely decide these cases early: (i) Article III standing for injunctive relief under Title II, and (ii) Rooker-Feldman/Younger limits on federal-court intervention in state child-support judgments and enforcement. The panel also underscored a remedial consequence that matters in practice: dismissals for lack of standing or subject-matter jurisdiction must be without prejudice.

2. Summary of the Opinion

• ADA (Title II): The court held that Glasco lacked standing to pursue injunctive relief (the only remedy he sought) because his amended complaint alleged only past denial of access/accommodations for a hearing that had already occurred and did not allege facts supporting a real and immediate threat of future discrimination. The court therefore required dismissal for lack of standing and instructed that the ADA claim be dismissed without prejudice.
• § 1983 Due Process / Unlawful Enforcement / Equal Protection: The court held these claims were barred by the Rooker-Feldman doctrine because they complained of injuries caused by the state child-support judgment and sought relief that, in substance, would require the federal court to review and reject that judgment (e.g., injunctions restricting garnishment and compelling crediting of SSA offsets). Because Rooker-Feldman is jurisdictional, the claims had to be dismissed without prejudice.
• Alternative abstention: The court added that even if Rooker-Feldman did not apply, Younger abstention would justify withholding equitable relief to avoid interfering with state child-support proceedings, given the important state interest in family relations and the absence of allegations showing Alabama courts were an inadequate forum.
• Preliminary injunction / sealing: The panel affirmed the district court’s handling of pretrial motions, noting the court denied the temporary restraining order and the record did not show a separate motion to seal (only a request within the prayer for relief).
• Disposition: The Eleventh Circuit vacated and remanded in part with instructions to dismiss certain claims without prejudice, and affirmed in part.

3. Analysis

3.1 Precedents Cited (and How They Shaped the Outcome)

A. Pleading, screening, and appellate framing

• Henley v. Payne and 28 U.S.C. § 1915(e)(2)(B): The court anchored the district court’s authority to dismiss an in forma pauperis complaint sua sponte, and applied de novo review using Rule 12(b)(6)-type standards.
• Haynes v. McCalla Raymer, LLC: Supported affirmance “on any ground supported by the record,” which became important because the panel affirmed/required dismissal on standing/jurisdiction grounds even while expressing doubts about the district court’s merits analysis of the ADA pleading.
• Bell Atl. Corp. v. Twombly and Ashcroft v. Iqbal, plus Edwards v. Prime, Inc.: Established the plausibility standard and the requirement to accept well-pleaded facts as true at the motion-to-dismiss stage.
• Woldeab v. Dekalb Cnty. Bd. of Educ.: Framed amendment principles for pro se plaintiffs (at least one chance to amend when a more carefully drafted complaint might state a claim), though the appeal ultimately turned on jurisdictional barriers rather than an amendment remedy.
• Campbell v. Air Jam. Ltd., Albra v. Advan, Inc.: The panel reiterated liberal construction of pro se filings, while requiring compliance with procedural rules.
• Timson v. Sampson and Sapuppo v. Allstate Floridian Ins. Co.: These abandonment doctrines narrowed the live issues on appeal. The court deemed Glasco to have abandoned ADA arguments against certain defendants (including unnamed ADHR employees and, effectively, ADHR itself) by failing to adequately brief them.

B. Sovereign immunity and Title II ADA architecture (discussed, but not outcome-determinative here)

• Nichols v. Ala. State Bar and Manders v. Lee: Provided the Eleventh Amendment “arm of the State” framework, relevant because defendants included state entities.
• Black v. Wigington: Supplied the general test for congressional abrogation of sovereign immunity.
• Tennessee v. Lane and United States v. Georgia (with Miller v. King): These cases define when Title II validly abrogates immunity (especially for access-to-courts claims) and require a claim-by-claim analysis. The panel cited them to situate Title II doctrine, but resolved Glasco’s requested relief on standing grounds.
• Shotz v. Cates: Crucial for two propositions: (i) county courts are “public entities,” and court proceedings are “services, programs, or activities” under Title II, and (ii) standing for ADA injunctive relief requires plausible allegations of future discrimination.
• Ingram v. Kubik: Provided the elements of a Title II discrimination claim.
• Silberman v. Miami Dade Transit and Liese v. Indian River Cnty. Hosp. Dist.: Cited for the heightened requirement of “deliberate indifference” for damages, though damages were not the live remedy because Glasco sought only injunctive relief.

C. Standing as a jurisdictional bar to ADA injunctive relief

• United States v. Harris: Reinforced the appellate court’s sua sponte duty to examine jurisdiction.
• Nat'l Org. for Women, Inc. v. Scheidler: Standing may be reviewed at any stage.
• Houston v. Marod Supermarkets, Inc.: Supplied the “real and immediate” future-injury requirement for injunctive relief.
• Wiand v. ATC Brokers Ltd.: Established that when a plaintiff lacks standing, dismissal must be without prejudice.

D. Rooker-Feldman and abstention barriers in child-support enforcement disputes

• Lozman v. City of Riviera Beach: Set de novo review for application of Rooker-Feldman.
• Exxon Mobil Corp. v. Saudi Basic Indus. Corp.: Defined the core of Rooker-Feldman—federal suits by state-court losers complaining of injury caused by the state judgment and seeking federal review/rejection.
• Behr v. Campbell: Provided the modern Eleventh Circuit’s “claim-by-claim” Rooker-Feldman approach and cautioned the doctrine occupies “narrow ground.” It also highlighted that damages-only claims for independent constitutional violations may proceed, while judgment-rejection claims may not.
• Efron v. Candelario: Functioned as the closest factual analog the panel relied on. The court used Efron to stress that a plaintiff cannot evade Rooker-Feldman by disclaiming an intent to overturn a state order when the requested federal relief would, in substance, require rejecting the state court’s rulings.
• Stalley ex rel. U.S. v. Orlando Reg'l Healthcare Sys., Inc. and Gardner v. Mutz: Confirmed that jurisdictional dismissals are not on the merits and must be without prejudice, and that dismissal “with prejudice” is reversible error when the court lacks jurisdiction.
• Old Republic Union Ins. Co. v. Tillis Trucking Co., Leonard v. Ala. State. Bd. of Pharmacy, and Younger v. Harris: Explained the (narrow) Younger abstention doctrine requiring federal courts to refrain from enjoining certain ongoing state proceedings absent special circumstances.
• Tokyo Gwinnett., LLC v. Gwinnett Cnty. and Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass'n: Provided the three-factor test for Younger (ongoing proceeding, important interest, and adequate opportunity to raise federal issues).
• 31 Foster Children v. Bush: Clarified that the “ongoing proceeding” factor is met when requested federal relief would interfere with state proceedings.
• Pennzoil Co. v. Texaco, Inc. and Moore v. Sims: Supported the propositions that states have important interests in administering their judicial systems and that family relations are a traditional area of state concern—making abstention especially salient in domestic matters.

E. Pretrial motions and preliminary injunction practice

• Harbourside Place, LLC v. Town of Jupiter, Fla.: Standard of review for preliminary injunction rulings (abuse of discretion).
• Chudasama v. Mazda Motor Corp. and Smith v. Miorelli: Addressed when failure to rule on significant motions can be an abuse of discretion and how abuse of discretion is defined. The panel applied these to uphold the district court’s handling of the TRO/reconsideration and the absence of a separate sealing motion in the record.

3.2 Legal Reasoning

A. The ADA claim failed not (primarily) on pleading merits, but on standing

Glasco’s amended complaint alleged that “The Jefferson County Family Court failed to provide reasonable accommodations for Plaintiff's disability, including remote hearing access, procedural guidance, and flexibility for physical limitations . . . in violation of Title II of the ADA.” The panel expressed “serious doubts” about whether the district court properly viewed the allegations in the light most favorable to Glasco, signaling that a plausible Title II access-to-courts theory may have been at least arguable.

But the court treated standing as decisive because Glasco sought only prospective equitable relief. Under Shotz v. Cates and Houston v. Marod Supermarkets, Inc., a plaintiff lacks standing to seek an injunction under the ADA unless the complaint alleges facts supporting a “real and immediate” likelihood of future discrimination. Glasco’s pleadings identified a past denial of access for a hearing that “has already occurred,” and did not allege future interaction with the court or a continuing policy likely to affect him again. That deficiency deprived the federal courts of jurisdiction.

Critically, the panel corrected the district court’s form of dismissal: because lack of standing is jurisdictional, the ADA claim had to be dismissed without prejudice (citing Wiand v. ATC Brokers Ltd.).

B. The civil-rights claims were jurisdictionally barred because they sought, in substance, to revise the state child-support judgment

Glasco’s § 1983 theories (due process, unlawful enforcement, equal protection) focused on ADHR’s garnishment/enforcement of child support and an asserted failure to credit SSA-related offsets (including “SSDI auxiliary benefits paid to dependent children”). He sought injunctions prohibiting “future garnishment of any income, including SSDI” and compelling ADHR to credit those benefits.

Applying Exxon Mobil Corp. v. Saudi Basic Indus. Corp., Behr v. Campbell, and particularly Efron v. Candelario, the court looked past labels to the “substance” of the requested relief. Even though Glasco asserted he did not seek to overturn or modify the child-support order, the panel concluded the federal court could not grant his injunctions without effectively reviewing and rejecting the state court’s child-support calculation and judgment. In the court’s view, the “necessary and obvious import” of Glasco’s allegations was that the state order itself—as enforced—was the source of the constitutional injury.

That framing placed the claims within Rooker-Feldman’s core: a state-court loser complaining of an injury caused by the state judgment and seeking federal-court relief that would negate or revise that judgment’s effect.

As with the ADA claim, the panel emphasized remedial precision: because Rooker-Feldman is jurisdictional, dismissal must be without prejudice (citing Stalley ex rel. U.S. v. Orlando Reg'l Healthcare Sys., Inc. and Gardner v. Mutz).

C. Younger abstention provided an alternative rationale (especially given the requested equitable interference)

The panel also explained that even if Rooker-Feldman did not bar the claims, the district court did not abuse its discretion in determining that Younger abstention was warranted “to avoid interfering with state proceedings,” to the extent proceedings were ongoing. The factors supported abstention: ongoing child-support proceedings (if still pending), important state interests in family relations (Moore v. Sims), and no pleaded basis to conclude Alabama courts were an inadequate forum (Pennzoil Co. v. Texaco, Inc.; Leonard v. Ala. State. Bd. of Pharmacy).

D. Pretrial motions: no abuse of discretion

On the preliminary-injunction issue, the panel noted the district court did deny a temporary restraining order and denied reconsideration, and found no “immediate or irreparable injury” or likelihood of success on the merits. On sealing, the panel found no separate motion to seal in the record—only a request embedded in the amended complaint’s demand for relief.

3.3 Impact

• Sharper pleading for ADA injunction standing in court-access disputes: Litigants alleging failure to accommodate in a particular hearing must plead more than a past denial. They must allege facts supporting a plausible, non-speculative likelihood of future exposure—e.g., upcoming hearings, repeated proceedings, or a continuing policy likely to recur.
• Child-support enforcement challenges face a high federal jurisdictional wall: Where requested relief would stop garnishment, re-credit payments, or otherwise alter the practical effect of a state support order, the decision confirms the Eleventh Circuit will treat the claim as a de facto appeal of the state judgment under Efron v. Candelario.
• Remedy matters, not just theory: The contrast to Behr v. Campbell is instructive: damages for independent constitutional wrongs may sometimes avoid Rooker-Feldman, but broad injunctions targeting enforcement of support orders are far more likely to trigger jurisdictional bars and/or Younger abstention.
• Practical consequence of “without prejudice” dismissals: By requiring without-prejudice dismissal, the court preserves a plaintiff’s ability to refile if jurisdictional facts change (e.g., future hearings creating an injunctive standing basis) or to pursue claims in the proper forum (often state court).

4. Complex Concepts Simplified

• Standing (for injunctions): To get a court order telling a government entity to change future conduct, a plaintiff must show not only past harm but a real, immediate risk of being harmed again. Past-only harm usually supports damages, not injunctions.
• Rooker-Feldman doctrine: Federal district courts are not appellate courts for state-court judgments. If a federal claim would require the district court to decide the state court got it wrong and effectively undo the judgment, the federal court lacks jurisdiction.
• Younger abstention: Even when federal jurisdiction exists, federal courts often avoid issuing injunctions that would interfere with certain ongoing state proceedings—especially those involving core state interests like family relations—unless exceptional circumstances exist.
• “With prejudice” vs. “without prejudice”: “With prejudice” ends the claim on the merits and typically bars refiling. But when a case is dismissed because the court lacks jurisdiction (standing, Rooker-Feldman), it must be “without prejudice,” because the court never reached the merits.
• Abandonment on appeal: Even pro se appellants must clearly raise and argue issues in their opening brief; otherwise, the appellate court treats them as abandoned.

5. Conclusion

The Eleventh Circuit’s decision establishes (and forcefully reiterates) two controlling thresholds for federal challenges arising out of state domestic-relations enforcement: (1) Title II ADA plaintiffs seeking only injunctive relief must allege a real and immediate likelihood of future discrimination; a concluded hearing, without more, does not confer standing. (2) § 1983 claims that would, in substance, restrain or recalibrate enforcement of a state child-support judgment are barred by Rooker-Feldman (and, alternatively, may warrant Younger abstention). Finally, the opinion underscores a procedural safeguard with real downstream consequences: jurisdictional dismissals—whether for standing or Rooker-Feldman—must be entered without prejudice.