Harley v. Contra Costa County Children and Family Services
June 26, 2026·2:24-cv-03059-TLN-JDP·Unpublished·By Raj Patel
The Ninth Circuit affirmed a district court dismissal of a plaintiff's challenge to a state custody order. The appellate panel held that the claims were barred by the Rooker-Feldman doctrine as a forbidden de facto appeal.
Background
Raoul E. Harley, Jr., proceeding pro se, appealed from a district court judgment dismissing his action challenging a state court custody order.
The court’s reasoning
The panel reviewed the dismissal de novo and concluded the district court properly applied the Rooker-Feldman doctrine. The court found Harley’s claims amounted to a forbidden de facto appeal of a prior state court judgment or were inextricably intertwined with that judgment.
What it means going forward
The ruling reinforces that federal courts lack jurisdiction to review state court judgments through civil actions that function as appeals, even when brought by pro se litigants.
