Background
Kevin Glasco, proceeding pro se, appealed a district court’s sua sponte dismissal of his amended complaint against the Alabama Department of Human Resources and the Jefferson County Family Court. Glasco alleged violations of Title II of the Americans with Disabilities Act and his civil rights in connection with child-support proceedings and the collection of payments owed pursuant to a state court judgment.
The court’s reasoning
The court held that Glasco lacked standing to pursue injunctive relief under the ADA because his complaint failed to allege facts showing a real and immediate threat of future discrimination. Regarding his civil rights claims, the court applied the Rooker-Feldman doctrine, concluding that the substance of Glasco’s claims sought to review and reject the Jefferson County Family Court’s child support judgment. The court determined that the district court erred in dismissing these claims with prejudice and should have dismissed them without prejudice.
What it means going forward
The case is remanded to the district court to dismiss the ADA claim and the civil rights claims without prejudice, allowing Glasco to potentially refile the ADA claim if he can allege future injury, while the civil rights claims remain barred by federal jurisdictional limits on reviewing state court judgments.