Kasse Leone Barta & on behalf of joint minor Child v. Andrew Jaymes Hallberg
Kasse Leone Barta & on behalf of joint minor Child v. Andrew Jaymes Hallberg, Paula Duggan T. Vra, Jennifer Christensen, Kerri Jensen, Jan Beucher, and Lu Ann Carpenter
- Eric Tostrud
- 0:25-cv-04486
- U.S. District Court · District of Minnesota
- 6
In Barta v. Hallberg, Judge Tostrud dismissed Kasse Leone Barta's federal lawsuit challenging Minnesota state custody orders, ruling the court lacked jurisdiction under the Rooker-Feldman doctrine.
Parents involved in state court child custody disputes who attempt to challenge state court custody orders in federal court; litigants who have lost in state court and seek federal review of those decisions; pro se litigants attempting to represent their minor children in federal proceedings.
What happened
In Kasse Leone Barta & on behalf of joint minor Child v. Andrew Jaymes Hallberg et al., Kasse Leone Barta filed a federal lawsuit arising from a long-running Minnesota child custody dispute. Barta alleged that a Scott County state court improperly entered custody orders favoring Andrew Jaymes Hallberg, despite a 2016 Carver County order granting her primary physical custody of their child, L.L.B. She claimed the Scott County orders were void for lack of jurisdiction and were obtained through a conspiracy involving a state judge, court administrators, and social-services employees who allegedly had family ties to Hallberg.
Barta's complaint asked the federal court to declare all post-2008 Scott County custody orders void and unenforceable, restore her custody rights under the 2016 Carver County order, and enjoin defendants from enforcing the Scott County orders. She also brought claims for due process violations, intentional infliction of emotional distress, and conspiracy under federal civil rights law. She additionally applied to proceed without paying court filing fees.
Judge Eric C. Tostrud dismissed the complaint without prejudice for lack of jurisdiction, applying the Rooker-Feldman doctrine — a rule that prohibits federal district courts from reviewing or overturning state court judgments. The court found that Barta was essentially asking a federal court to undo state court custody rulings she lost, which falls squarely within that jurisdictional bar. The court also noted that even if jurisdiction existed, the complaint would fail on multiple additional grounds, including judicial immunity, lack of state-actor status for Hallberg, and other deficiencies. Barta's application to proceed without paying fees was denied as moot.
The detailed version
- Kasse Leone Barta & on behalf of joint minor Child v. Andrew Jaymes Hallberg · No. 0:25-cv-04486
- Eric Tostrud
- Dec. 22, 2025
Background
This case arises from a long-running child custody dispute in Minnesota state courts. Plaintiff Kasse Leone Barta alleged that in May 2016, a Carver County state court entered a "permanency order" granting her and Defendant Andrew Jaymes Hallberg joint legal and physical custody of their minor child, L.L.B., with Barta having primary physical custody. Barta contended that this order vested the Carver County court with exclusive, continuing jurisdiction over custody of L.L.B. under Minnesota law.
Despite this, Barta alleged that a Scott County state court later entered multiple custody modification orders in a previously closed paternity case, shifting custody in favor of Hallberg. Barta argued these Scott County orders were entered without jurisdiction and without compliance with required Minnesota statutory procedures, and therefore were void. She further alleged that Hallberg "procured" these orders through a conspiracy with several individuals connected to the court system, some of whom the complaint alleged were related to Hallberg's family: Defendant Judge Paula Vraa (a Minnesota state district judge who presided over Scott County proceedings); Defendant Kerri Jensen (a Carver County social-services employee); Defendant Jennifer Christensen (a Carver County court administrator); Defendant Jan Beucher (a Scott County child-support officer); and Defendant Lu Ann Carpenter, also known as Lu Ann Bayer (a court-operations administrator).
Barta alleged that as a result of the void orders, she was denied parenting time, and that L.L.B. was placed in unsafe or inappropriate custody, causing the child emotional distress and physical injury, including PTSD symptoms requiring in-patient psychiatric hospitalization. Barta reported that her attempts to challenge the Scott County orders through the Minnesota Court of Appeals were unsuccessful.
Claims
The complaint pressed four counts:
- Count 1 sought a declaration that all Scott County custody orders entered after December 31, 2008 are void because the May 2016 Carver County order triggered exclusive continuing jurisdiction under Minnesota law. - Count 2 asserted violations of Barta's and L.L.B.'s rights to procedural and substantive due process under the U.S. Constitution (and parallel Minnesota constitutional protections), based on custody changes made without lawful jurisdiction or required procedures. - Count 3 asserted a state-law claim for reckless and intentional infliction of emotional distress. - Count 4 alleged that defendants acted in concert to misuse legal processes in violation of 42 U.S.C. § 1985 (a federal civil rights conspiracy statute), depriving Barta of custody and parenting rights.
For relief, Barta sought a declaration that the Scott County orders are void and unenforceable, injunctive relief restoring her custody rights under the May 2016 order, an injunction against enforcement of the Scott County orders, an order requiring expedited review by the Carver County court, and additional equitable relief including potential damages and costs. Barta also applied to proceed in forma pauperis — that is, to proceed without paying court filing fees due to financial hardship.
Legal Analysis
Rooker-Feldman Doctrine
The court dismissed the action on jurisdictional grounds, applying the Rooker-Feldman doctrine — a rule derived from two Supreme Court cases (Rooker v. Fidelity Trust Co. and District of Columbia Court of Appeals v. Feldman) holding that lower federal courts have no jurisdiction to review or reverse state court judgments, except in the narrow context of federal habeas corpus (a separate type of proceeding to challenge unlawful detention). Federal district courts may not function as de facto appellate courts over state court decisions.
The doctrine bars cases brought by "state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments," quoting Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005).
The court found that Barta was, in substance, a state-court loser seeking federal review of state custody orders. The complaint explicitly asked the federal court to declare those orders void, enjoin their enforcement, and restore custody rights. This falls squarely within the Rooker-Feldman bar, depriving the court of subject-matter jurisdiction (the court's legal authority to hear the type of case at all).
Additional Grounds for Dismissal (Noted in Footnote)
The court stated that even if jurisdiction existed, the complaint would be subject to dismissal under 28 U.S.C. § 1915(e)(2)(B) — a statute requiring courts to screen complaints filed by litigants seeking to proceed without paying fees — for failure to state a claim on which relief may be granted. The court identified several independent deficiencies:
- Representation of minor child: As a pro se (self-represented, non-attorney) litigant, Barta cannot represent the legal interests of her minor child in federal court, citing Crozier ex rel. A.C. v. Westside Cmty. Sch. Dist., 973 F.3d 882, 887 (8th Cir. 2020).
- Immunity barriers: Judge Vraa is entitled to absolute judicial immunity from suit for actions taken in her judicial capacity. Court administrators are protected by quasi-judicial immunity. State officials sued in their official capacities are largely shielded by the Eleventh Amendment (which generally bars federal suits against states and their agencies).
- Section 1983 and § 1985 claims against Hallberg: Claims under 42 U.S.C. § 1983 (a federal statute allowing civil rights suits against persons acting under color of state law) require that the defendant be a state actor. Hallberg is a private individual, and the complaint's conclusory allegations of conspiracy were insufficient to convert his private conduct into state action or to state a valid claim under § 1985(3) (which covers conspiracies to deprive persons of civil rights).
- Monell liability: The complaint failed to plead any municipal policy or custom of the kind required to hold county defendants liable under Monell v. Department of Social Services, 436 U.S. 658, 694 (1978), which sets the standard for suing local governments under §
- 5. Supplemental jurisdiction: Had the federal claims been dismissed, the court stated it would decline to exercise supplemental jurisdiction (the authority to also decide related state-law claims) over any remaining state-law claims.
Disposition
The court dismissed Barta's complaint without prejudice for lack of jurisdiction. A dismissal without prejudice means the case is ended in this court but does not bar the plaintiff from filing a new action. Barta's application to proceed without paying filing fees was denied as moot (meaning the dismissal made the fee question irrelevant).
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.