Haskell v. Fadem

Background

Jeffrey Haskell alleged that he lost custody of his two children in 2019 after a social-media confrontation. He further alleged that, during later family-court proceedings, therapist Marcia Clark and attorneys BJ Fadem and Nicole Ford conspired with the family-court judge to falsely tell him that one child was transgender and self-mutilating and that the other was suicidal. Haskell alleged that the defendants used those statements to cause him anxiety, deny him custody and visitation, and prolong fees charged to county taxpayers. He also alleged that the defendants acted against him because he supported President Donald Trump.

The complaint asserted four claims: (1) violation of Fifth and Fourteenth Amendment parental and due-process rights under 42 U.S.C. § 1983; (2) conspiracy under 42 U.S.C. § 1985(3), including an alleged effort to take away Haskell’s right to vote because of his membership in a class of Trump supporters; (3) a request for a declaration that making parent-child contact depend on payment of therapist fees was unconstitutional; and (4) fraud and willful misconduct under California law.

Rulings on the Motion

Defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which challenges federal subject-matter jurisdiction, and Rule 12(b)(6), which challenges whether a complaint adequately states a claim. The court granted defendants’ request for judicial notice of filings from state family-law and restraining-order proceedings. It took notice of the documents’ existence and contents, but not the truth of factual statements in them.

The court held that Haskell adequately alleged standing for his parental-rights claims. Standing requires an injury that is concrete and connected to the defendants’ conduct, with a likely remedy available from the court. The court concluded that the state-court record did not directly refute Haskell’s account and that factual disputes connected to both standing and the merits could not be resolved at this stage.

The court also held that neither the Rooker-Feldman doctrine nor the domestic-relations exception prevented it from hearing the case. Rooker-Feldman generally bars a federal suit that challenges a state-court judgment and seeks relief from that judgment. The court found that Haskell’s claims sought damages rather than expressly overturning the state-court judgment, and that his allegations concerned wrongdoing by adverse parties rather than legal error by the state court. The court also concluded that the domestic-relations exception did not apply because three claims arose under federal law.

Disposition of the Claims

The court dismissed Claims 1 and 2 as time-barred. Those claims were subject to a two-year limitations period. The court concluded that the injuries supporting the claims occurred before December 20, 2022, two years before Haskell filed the action. It rejected Haskell’s argument that a discovery rule delayed the start of the limitations period, reasoning that the complaint showed he had reason to suspect the alleged wrongdoing before December 20, 2022.

The court dismissed Claim 3 for failure to state a claim. Haskell sought a declaration concerning therapist fees, but the complaint alleged only that he had been required to pay those fees in the past and did not allege an ongoing payment requirement. The court stated that declaratory relief cannot be based solely on a completed violation.

The court declined to exercise supplemental jurisdiction over Claim 4, the California fraud and willful-misconduct claim, because it had dismissed all of the federal claims. The court said it would reconsider that decision if Haskell filed an amended complaint containing federal claims that survived a motion to dismiss.

The court granted defendants’ motion to dismiss with leave to amend and ordered any amended complaint filed within 28 days. It deferred ruling on defendants’ request to strike the state-law claim under California’s anti-SLAPP statute, allowing defendants to renew that request later. The order did not resolve the anti-SLAPP request on the merits.