In February 2024, James Heyward lost his home after Diana Moreland, a judge in Florida's Twelfth Judicial Circuit, issued a final judgment foreclosing on his property. Four months later, Heyward filed a federal lawsuit in the Middle District of Florida, suing Judge Moreland in her individual capacity. Heyward alleged that Moreland was impersonating a judge because she had never taken the oath required by the first law passed by Congress, codified at 4 U.S.C. § 101. His complaint sought two types of relief: declaratory judgments declaring all of Moreland's acts as a judge void, and monetary damages exceeding $10 million. The district court dismissed the complaint with prejudice, ruling that the claims were barred by absolute judicial immunity, that the court lacked subject-matter jurisdiction under the Rooker-Feldman doctrine, and that the complaint failed to state a claim. Heyward appealed, arguing that the dismissal violated statutory interpretation principles.
The Eleventh Circuit began its analysis with the Rooker-Feldman doctrine, a jurisdictional bar that prevents federal courts from reviewing state court judgments. The court explained that this doctrine bars 'all appeals of state court judgments—whether the plaintiff admits to filing a direct appeal of the judgment or tries to call the appeal something else.' Because Heyward's claims sought to invalidate the state court foreclosure judgment, they effectively functioned as an impermissible appeal. The court noted that the proper remedy for a losing state-court litigator is a direct appeal to the state appellate system, not a federal lawsuit. Even if Rooker-Feldman did not apply, the court held that absolute judicial immunity bars Heyward's claims. This immunity applies to state judges acting in their judicial capacity, even when they act in excess of their jurisdiction, provided they do not act in the 'clear absence of all jurisdiction.' Heyward argued that Moreland was not a judge because she allegedly failed to take the required oath. The court rejected this, noting that the de facto officer doctrine protects the validity of official acts performed by someone who claims to hold an office, is in possession of it, and performs its duties. The court found that Heyward's own complaint admitted Moreland was in possession of the office and performing duties. Therefore, she is a de facto judge, and absolute immunity applies to her just as it does to a de jure judge. The court also addressed Heyward's argument that the dismissal rendered the oath statute inoperative, clarifying that the court did not interpret the statute but rather dismissed the case on jurisdictional and immunity grounds, leaving the statute's validity for another day.
The decision leaves Heyward without a federal remedy to challenge the state court foreclosure order or seek damages from Judge Moreland. It reinforces the principle that federal courts cannot serve as appellate bodies for state court decisions and confirms that judges are immune from suits challenging their authority based on alleged oath deficiencies, provided they are acting in their judicial capacity. The dismissal with prejudice means Heyward cannot refile the same claims in federal court.