Washeleski v. Monazamfar

Background

Pawl Washeleski, representing himself, brought this action based on his child-custody matter in Santa Clara County Family Court. He alleged that Judge Brooke Blecher made biased rulings and evidentiary errors and conspired with Golnesa Monazamfar, a private attorney who represented Washeleski’s former partner. Washeleski also accused Monazamfar of perjury, forgery, mail fraud, obstruction of justice, and other misconduct. He alleged that Stephanie Finelli, another private attorney, knew about the alleged misconduct but did not intervene. He further alleged that the Campbell Police Department, Santa Clara Police Department, and Santa Clara County Sheriff’s Office enforced fraudulent court orders and blocked police reports he tried to file.

The court understood Washeleski to be asserting claims under the Racketeer Influenced and Corrupt Organizations Act, 42 U.S.C. §§ 1983 and 1985(3), and the Americans with Disabilities Act. The court had granted his application to proceed without paying the filing fee and therefore screened the complaint under 28 U.S.C. § 1915(e)(2).

Reasons for Dismissal

The court dismissed the complaint for failing to comply with Federal Rule of Civil Procedure 8. That rule requires a short and plain statement giving defendants fair notice of the claims. The approximately 270-page complaint combined separate files and letters sent to various government agencies, police departments, and courts. It also included a 72-page list of 518 alleged violations and was supplemented by numerous other filings. The court found that these materials did not provide a short and plain statement of the claims.

The court also held that it lacked subject-matter jurisdiction over claims challenging Judge Blecher’s state-court rulings. The Rooker-Feldman doctrine prevents a federal district court from acting as an appeal court reviewing a state-court judgment. The court found that Washeleski sought to nullify custody orders, financial penalties, and restraining orders, and that claims against the police defendants based on enforcement of those orders were closely connected to the state-court judgments. The court also held that sovereign immunity barred the claims against Judge Blecher seeking retrospective relief, such as staying or vacating the state-court judgments.

Claim-Specific Rulings

The court held that the racketeering claim failed because Washeleski did not plausibly allege an association-in-fact enterprise. In particular, he did not adequately allege that the defendants associated for a common purpose, had relationships among themselves, or operated together for a sufficient period. Any racketeering-conspiracy claim also failed along with the underlying racketeering claim. The court additionally held that judicial immunity barred damages claims against Judge Blecher based on judicial rulings and management of court proceedings.

The court held that the claim under 42 U.S.C. § 1983 failed against Monazamfar and Finelli because private lawyers are not state actors merely because they represent clients in court. The court also found no plausible allegation of an agreement or meeting of the minds between those attorneys and a state actor. The § 1983 claim against Judge Blecher failed because Washeleski sought injunctive relief without alleging that a declaratory decree had been violated or that declaratory relief was unavailable. Claims against the police defendants failed because enforcement of facially valid court orders is generally immune conduct and because Washeleski did not plausibly allege a municipal policy or custom concerning the failure to take reports or act on his complaints.

The claim under 42 U.S.C. § 1985(3) also failed. Washeleski did not plausibly allege a conspiracy or racial or other class-based discriminatory motive, and the court noted that such a claim also requires a viable § 1983 claim. The court held that the Americans with Disabilities Act claim was deficient because individual defendants could not be held liable in the asserted circumstances, judicial immunity barred the claim against Judge Blecher in her official capacity, and the court found no relevant allegations supporting the claim against the police defendants.

Leave to Amend

The court dismissed the complaint in its entirety but granted leave to amend because this was its first ruling on the legal sufficiency of the claims and Washeleski was representing himself. It ordered that any amended complaint be filed as one document identifying each claim, defendant, legal theory, and requested relief. References to Washeleski’s minor children were required to use initials rather than full names. The court warned that it could dismiss a deficient amended complaint without granting further leave to amend.

Other Motions and Case Orders

The court denied Washeleski’s motion for a preliminary injunction seeking to halt enforcement of state-court custody, financial, and restraining orders. It found that he had not shown that the defendants received the required notice, that federal law limited injunctions against judicial officers, that the requested relief would improperly review state-court judgments, and that he had not shown a likelihood of success or sufficiently serious questions on the merits.

The court denied two motions for sanctions under Rule 11 because Washeleski did not show compliance with the required 21-day notice, or safe-harbor, procedure, and because the alleged misconduct occurred in prior state-court proceedings rather than in filings in this case. It denied the motion for early discovery and evidence preservation because the claims had been dismissed, the requests were broad and unclear, and Washeleski had not shown good cause. It denied the motion to appoint counsel because he had not shown a likelihood of success or exceptional circumstances; the denial was without prejudice to the court appointing counsel on its own initiative. The court also denied the motion to file a supplemental declaration, while allowing Washeleski to include relevant facts from that proposed declaration in an amended complaint.

The court suspended service by the United States Marshals Service until further order finding that Washeleski had plausibly stated a claim, vacated the December 17, 2025 case-management conference, and directed Washeleski to the court’s disability-accommodation resources.