Hart v. Thompson

Background

Malcolm Hart filed this action without a lawyer against Denetra Thompson and Jennifer Seiderman, identified in the opinion as Bronx County Family Court Support Magistrates. Hart alleged that they violated his rights by issuing orders directing him to pay child support.

On June 12, 2023, the court dismissed the amended complaint for lack of subject-matter jurisdiction under the Rooker-Feldman doctrine, which generally prevents a federal district court from reviewing a state-court judgment. The court also relied alternatively on the domestic-relations abstention doctrine. In addition, it dismissed Hart’s claims against Thompson and Seiderman based on judicial immunity, finding that the claims were frivolous and sought money from defendants protected from that relief. Judgment was entered the same day.

Hart filed a motion for reconsideration on June 27, 2023. Because the filing was not submitted within 14 days after judgment, the court did not treat it as a motion under the applicable local reconsideration rule. Instead, it treated the filing as a motion to alter or amend the judgment under Federal Rule of Civil Procedure 59(e) and a motion for relief from a judgment or order under Rule 60(b).

Rule 59(e) ruling

For a Rule 59(e) motion, the party must show that the court overlooked controlling law or factual matters previously presented. The court found that Hart had not made that showing. It said his motion largely repeated the facts and arguments from his complaint and amended complaint.

The court rejected Hart’s arguments that Thompson and Seiderman were not protected by judicial immunity because they were not judges or because they acted without jurisdiction. The court stated that absolute judicial immunity applies to New York Family Court Support Magistrates and found that Hart had alleged no facts showing that either defendant acted outside the scope of judicial responsibilities or jurisdiction. The court also found no facts supporting an exception to the statutory restriction on injunctive relief against judges under 42 U.S.C. § 1983. The court further found that Hart had not shown that it overlooked anything concerning its earlier jurisdiction and domestic-relations rulings. It therefore denied the motion under Rule 59(e).

Rule 60(b) ruling

Rule 60(b) permits relief from a judgment for specified reasons, including mistake, newly discovered evidence, misconduct, a void judgment, satisfaction or reversal of an earlier judgment, or another reason justifying relief. The court found that Hart had not shown that any of the first five grounds applied and denied relief under those grounds.

The court also denied relief under Rule 60(b)(6), which applies only for reasons different from those listed in the first five clauses and requires a reasonable filing time and extraordinary circumstances. The court found that Hart had not demonstrated extraordinary circumstances.

Disposition

The court denied Hart’s motion for reconsideration, including his requests under Rules 59(e) and 60(b). The action is closed. The Clerk of Court will accept only documents directed to the United States Court of Appeals for the Second Circuit. The court certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith and denied permission to appeal without paying filing fees.