Buxbaum v. Cornell

Background

Michael Buxbaum filed the complaint without a lawyer and paid the filing fee after the court directed him either to pay the fee or submit an application to proceed without prepaying it. He sued Acting Family Court Judge Keith Cornell and the Legal Aid Society of Rockland County, alleging violations of his due process rights in Rockland County Family Court.

Buxbaum alleged that the family court had entered orders that prohibited him from communicating with his child, required him to remain 100 yards away from the child, and prohibited him from attending the child's soccer games. He asked the federal court to assign the family-court matter to Referee Dean Richardson-Mendolsohn, prevent Judge Cornell from acting as the family-court judge in the matter, and assign a new attorney for the child. The opinion states that the status of the family-court proceedings was unclear.

Judicial Immunity

The court dismissed Buxbaum's claims against Judge Cornell under the doctrine of absolute judicial immunity. Judges are generally immune from damages lawsuits for actions taken within their judicial responsibilities. The protection does not apply when a judge acts outside the judge's judicial capacity or acts without any jurisdiction. The court found that Buxbaum did not allege facts showing either circumstance. Because the challenged actions arose from or related to cases before Judge Cornell, the court dismissed those claims under the statutory screening provisions cited in the order and treated them as frivolous for purposes of those provisions.

Claims Against the Legal Aid Society

The court also dismissed Buxbaum's claims against the Legal Aid Society of Rockland County. A civil-rights claim under 42 U.S.C. § 1983 requires facts showing that each defendant acted under state authority. The court described the Legal Aid Society as a private party and found that Buxbaum had not alleged that it worked for a state or other government body. The court therefore concluded that he had not stated a claim against that defendant under Section 1983.

Interference with State-Court Proceedings

The court ruled that Buxbaum's request for federal intervention in the family-court proceedings was barred by the Anti-Injunction Act. That federal law generally prohibits federal courts from issuing orders that stop state-court proceedings unless one of three statutory exceptions applies. The court found that Buxbaum had alleged nothing suggesting that an exception applied.

The court also applied the domestic-relations abstention doctrine. That doctrine generally requires federal courts to refrain from deciding federal-question claims involving domestic-relations matters when those matters can be fully and fairly resolved in state court. Because Buxbaum was asking the federal court to intervene in Rockland County Family Court proceedings, and his allegations did not suggest that he had been denied a full and fair hearing in state court, the court abstained from exercising federal-question jurisdiction over claims arising from the state-court orders and their enforcement.

The opinion added in a footnote that, if state-court proceedings were pending, another abstention doctrine might also apply to claims interfering with certain ongoing state proceedings. The court did not state that this additional doctrine was the basis for its disposition.

Leave to Replead and Disposition

Because Buxbaum was representing himself, the court granted him 30 days to allege facts supporting a claim for relief against proper defendants. The court expressed doubt that he could cure the complaint's defects but allowed amendment as a precaution. The amended complaint had to provide a short and plain statement of the facts supporting each claim, identify what each defendant did or failed to do, describe the injuries and requested relief, and repeat any facts or claims from the original complaint because the amended complaint would completely replace it.

The court dismissed Buxbaum's claims against Acting Family Court Judge Keith Cornell under judicial immunity. It dismissed Buxbaum's claims against the Legal Aid Society of Rockland County because it was a private party for purposes of the asserted Section 1983 claim. It also ruled that Buxbaum's request for intervention in the family-court proceedings was barred by the Anti-Injunction Act and the domestic-relations abstention doctrine. The court granted 30 days' leave to file an amended complaint against proper defendants and instructed the Clerk of Court to keep the matter open until a civil judgment was entered. The court certified that an appeal would not be taken in good faith and denied permission to proceed without prepaying fees for an appeal.