Wood v. Chidi
- James Donato
- 3:19-cv-04202
- U.S. District Court · Northern District of California
- 2
In Wood v. Chidi and Wood v. Williams, Judge Donato granted motions to dismiss Andrea Wood’s suits over child-custody conditions but allowed amendment.
Andrea Wood, Contra Costa County, and the county employees named as defendants in the two cases; the order also affected filings identifying or depicting a minor in Wood v. Williams.
What happened
Andrea Wood, representing herself, brought two lawsuits against Contra Costa County and some of its employees. Wood v. Chidi concerned the county’s refusal to provide her visitation with one child, while Wood v. Williams concerned another child being required to repeat a grade. Both cases arose from juvenile dependency hearings.
The court granted the motions to dismiss because federal courts generally cannot issue or alter child-custody orders under the domestic-relations exception to federal jurisdiction. The court also rejected Wood’s argument that the exception did not apply because she sought money damages, noting that she also requested orders against government defendants. Wood may amend both complaints by May 1, 2020.
Judge James Donato also struck two filings in Wood v. Williams because they disclosed a minor’s name and showed an identifiable picture of a minor. The court said no new claims or parties could be added without prior approval and warned that failing to respond by the deadline would result in dismissal without further leave to amend.
The detailed version
- Wood v. Chidi · No. 3:19-cv-04202
- James Donato
- Mar. 31, 2020
Background
This order resolved pending motions to dismiss in two cases brought by pro se plaintiff Andrea Wood against Contra Costa County and certain county employees. Both cases arose from juvenile dependency hearings. Wood v. Chidi challenged the county’s refusal to provide Wood visitation with one of her children. Wood v. Williams asserted claims based on another child being required to repeat a grade.
Motions to dismiss
The court granted the motions to dismiss in both cases. It held that the complaints fell within the domestic-relations exception to federal jurisdiction. That exception generally prevents federal courts from issuing divorce, alimony, or child-custody decrees. The court said Wood’s children had been removed from her custody during juvenile dependency proceedings and that her lawsuits challenged the conditions of state custody.
The court rejected Wood’s argument that the exception did not apply because she sought money damages. It said that argument was unsupported by precedent and, in any event, would not control because Wood also sought injunctive relief—court orders directed at the government defendants.
Other ruling
In Wood v. Williams, the court struck Docket Numbers 8 and 19. One filing contained the unredacted name of a person identified as a minor in other filings, and the other contained an identifiable picture of a minor. The court cited Federal Rule of Civil Procedure 5.2(a), which requires the name of a known minor to be redacted in federal court filings.
Amendment and disposition
The court granted Wood permission to amend both complaints by May 1, 2020, because it could not say that amendment would necessarily be futile. If the deadline was not feasible because of the public-health situation, the parties could agree to a different date by stipulation, or a party could ask the court for an extension. The court stated that failure to respond by May 1 would result in dismissal of Wood’s claims without further leave to amend. No new claims or parties could be added without the court’s prior approval. Judge James Donato also stated that defendants’ requests to declare Wood a vexatious litigant would be addressed in a separate order.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.