Background
The plaintiff, Loren Rancourt, appealed pro se from a district court dismissal of his action alleging claims against the Municipality of Anchorage, its prosecutor, state court judges, and court staff. The claims arose out of state and city court child custody and domestic violence proceedings.
The court’s reasoning
The panel reviewed the dismissal de novo and affirmed. The court held that judges Miller, Washington, and Bolger have absolute immunity for performing judicial acts unless acting in the clear absence of all jurisdiction. Judicial immunity extends to court staff Fuentes and Montgomery-Sythe for processing filings. The district court properly dismissed municipal prosecutor Shaffer, who is immune for acts of initiating and presenting the case related to the plaintiff’s violation of a domestic violence protective order. Claims for injunctive and declaratory relief were barred by the Rooker-Feldman doctrine, which prohibits federal district courts from exercising subject matter jurisdiction over a suit that is a de facto appeal from a state court judgment. The court also dismissed civil rights claims against the municipality because the plaintiff failed to allege specific facts establishing that a municipal policy or custom violated his constitutional rights. To the extent the plaintiff sought to allege a substantive due process claim related to the municipal code, he failed to allege sufficient facts to show that any municipal code provision shocks the conscience.
What it means going forward
The decision reinforces the breadth of judicial and prosecutorial immunity in the Ninth Circuit and confirms that federal courts cannot serve as appellate bodies for state court judgments under the Rooker-Feldman doctrine.