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Boston, MA - Criminal defense lawyer represented defendant with trying to void two Massachusetts Superior Court conditions of probation.

In 2009, at age nineteen or twenty, Jamie Melendez
impregnated fourteen-year-old Heather Tyler.2 Tyler gave birth in
2010. Upon pleading guilty in state court to the statutory rape
of Tyler, Melendez received a sentence of sixteen years of
probation. As conditions of probation, the sentencing judge
ordered Melendez to acknowledge paternity of the child and abide
by all orders of the Massachusetts Probate and Family Court.
In August 2012, after learning that Melendez sought to
obtain parental visitation rights in the Probate and Family Court,
Tyler filed a motion with the criminal sentencing judge seeking
reversal of the conditions of probation mentioned above. She
1 See Rooker v. Fid. Tr. Co., 263 U.S. 413 (1923); D.C. Court
of Appeals v. Feldman, 460 U.S. 462 (1983).
2 The record is unclear as to Melendez's exact age at the
time.
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objected to the conditions on the grounds that Melendez's
compliance with them would bind her to an unwanted sixteen-year
legal relationship with Melendez in the Probate and Family Court.
She requested that Melendez instead pay criminal restitution,
rather than child support, to relieve her of the burden of
continued engagement with him in family court. The sentencing
court denied Tyler's request. Tyler also sought relief from a
single justice of the Supreme Judicial Court of Massachusetts (SJC)
pursuant to Mass. Gen. Laws ch. 211, § 3. After the single justice
denied Tyler's motion, and Tyler appealed, the full SJC held oral
argument on Tyler's claims. The SJC affirmed the decision of the
single justice on the grounds that, as a victim of a criminal
offense, Tyler lacked standing to challenge Melendez's criminal
sentence. See H.T. v. Commonwealth, 989 N.E.2d 424, 425 (Mass.
2013). The SJC also advised that Tyler could "raise any claim of
error, including any claim that the [Probate and Family Court]
exceeded its lawful authority, in the ordinary appellate process."
Id. at 426.
Tyler then filed an action under the Federal Civil Rights
Act, 42 U.S.C. § 1983, in the District Court of Massachusetts,
seeking review of substantially the same grievances. In November
2013, the district court dismissed the action as barred by the
Eleventh Amendment. Tyler v. Massachusetts, 981 F. Supp. 2d 92,
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96 (D. Mass. 2013). The court also noted that the Burford3 and
Younger4 abstention doctrines counseled against adjudicating
Tyler's claims. Id. at 96–97. Tyler did not appeal.
In November 2013, Tyler filed a motion in the Probate
and Family Court seeking either to vacate the court's jurisdiction
or to terminate Melendez's parental rights. She contended that an
adult convicted of statutory rape should have no parental rights
with respect to a child born as a result of that crime. After the
family court denied her motion, Tyler sought review in the Appeals
Court of Massachusetts. The Appeals Court affirmed, holding that
"nothing in the language of [the family court statute, Mass. Gen.
Laws ch. 209C,] expressly limits its applicability solely to
children born as a result of lawful intercourse." H.T. v. J.M.,
No. 15–P–1042, 2016 WL 7046435, at *2 (Mass. App. Ct. Dec. 5,
2016), appeal denied, 75 N.E.3d 1130 (Mass. 2017). The Appeals
Court also discussed a 2014 amendment to the Massachusetts family
court statute,5 reasoning that since it was "apparent from [the
3 See Burford v. Sun Oil Co., 319 U.S. 315 (1943).
4 See Younger v. Harris, 401 U.S. 37 (1971).
5 In 2014, the Massachusetts legislature amended the family
court statute to specify that the family court should grant
visitation rights to a parent convicted of statutory rape only if
"visitation is in the best interest of the child" and "either the
other parent of the child conceived during the commission of that
rape has reached the age of 18 and said parent consents to such
visitation or the judge makes an independent determination that
visitation is in the best interest of the child." 2014 Mass.
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amendment's] language that it was designed to limit, rather than
to expand, the court's existing authority," the statute must have
previously authorized family courts to adjudicate the parental
rights of a parent convicted of statutory rape. Id. Finally, the
Appeals Court denied Tyler's plea to vacate jurisdiction as a
matter of public policy, noting that "the mother's desired
disposition [would] require us to treat the father more favorably
than other biological fathers, [and] it also would unfairly
disadvantage the child by depriving her of the right to receive
financial support from both parents." Id. at *3. In 2017, the
SJC denied Tyler's application for further appellate review. See
H.T. v. J.M., 75 N.E.3d 1130 (Mass. 2017).
Rather than seeking a writ of certiorari from the United
States Supreme Court, Tyler filed this action in the District of
Massachusetts, alleging that the "recent ruling of the
Massachusetts Supreme Judicial Court" violated her Fourth and
Fourteenth Amendment rights to due process, privacy, and equal
protection. She sought relief declaring the 2017 SJC decision
unconstitutional and "prevent[ing] all courts in the Commonwealth
[of Massachusetts] from asserting jurisdiction on behalf of
convicted rapists who impregnate their victims." The district
court decided that it did not have jurisdiction over the claims:

Legis. Serv. ch. 260 (West) (codified as amended at Mass. Gen.
Laws. ch. 209C, § 3(a)).
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"The Rooker-Feldman doctrine prevents consideration because
[Tyler] present[s] a dispute brought by an unsuccessful litigant
in the state courts seeking to have a lower federal court review
and reject a state court judgment rendered before the federal
litigation commenced." Tyler v. Supreme Judicial Court of Mass.,
292 F. Supp. 3d 555, 556 (D. Mass. 2018) (footnote omitted). This
appeal followed.
II.
Under the Rooker-Feldman doctrine, "lower federal courts
are precluded from exercising appellate jurisdiction over final
state-court judgments." Lance v. Dennis, 546 U.S. 459, 463 (2006).
The idea is that -- absent exceptions not present here -- the only
federal court with statutory jurisdiction to review a state court's
decision is the Supreme Court, and "an aggrieved litigant cannot
be permitted to do indirectly what he no longer can do directly."
Rooker, 263 U.S. at 416. The Rooker-Feldman doctrine bars
jurisdiction "only in the 'limited circumstances' where 'the
losing party in state court filed suit in federal court after the
state proceedings ended, complaining of an injury caused by the
state-court judgment and seeking review and rejection of that
judgment.'" Federación de Maestros de P.R. v. Junta de Relaciones
del Trabajo de P.R., 410 F.3d 17, 23–24 (1st Cir. 2005) (quoting
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 291
(2005)).
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The record makes plain that Tyler came to federal court
seeking an end-run around the SJC's 2017 decision allowing the
Probate and Family Court to adjudicate Melendez's parental rights.
Tyler's brief to this court concedes that her complaint "asks the
federal court to reverse the state court judgment." And the
complaint does indeed request that the district court "[d]eclar[e]
the Supreme Judicial Court's decision unconstitutional." The
complaint also repeatedly identifies the SJC's 2017 decision as
the exclusive cause of Tyler's injury. After discussing the statecourt proceedings culminating with the denial of her application
for further appellate review "by the Supreme Judicial Court on
January 26, 2017," Tyler details three counts all challenging that
decision. Count I alleges that the "ruling threatens Plaintiff's
rights by exposing Plaintiff to an unlawful restraint on her
liberty and a seizure of her person"; Count II alleges that the
"ruling threatens Plaintiff's liberty and privacy"; and Count III
alleges that the "decision violates Plaintiff's equal protection
rights." "Where federal relief can only be predicated upon a
conviction that the state court was wrong, it is difficult to
conceive the federal proceeding as, in substance, anything other
than a prohibited appeal of the state-court judgment." Hill v.
Town of Conway, 193 F.3d 33, 39 (1st Cir. 1999) (quoting Pennzoil
Co. v. Texaco, Inc., 481 U.S. 1, 25 (1987) (Marshall, J.,
concurring)).
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Tyler seeks haven from the application of this doctrine
by arguing that, "[a]lthough [she] raised the federal issues in
every state court proceeding, Rooker-Feldman poses no bar because
none of her federal claims was actually decided by any state
court." The record contradicts this assertion; in ruling against
Tyler, the Massachusetts Appeals Court wrote that it did not
"overlook[]" any of her contentions, but rather found "nothing in
them that require[d] discussion." H.T. v. J.M., 2016 WL 7046435,
at *3 n.10 (quoting Dep't of Revenue v. Ryan R., 816 N.E.2d 1020,
1027 (Mass. App. Ct. 2004)). Moreover, the Rooker-Feldman
jurisdictional bar "is not contingent upon an identity between the
issues actually litigated in the prior state-court proceedings and
the issues proffered in the subsequent federal suit. Instead, the
critical datum is whether the plaintiff's federal suit is, in
effect, an end-run around a final state-court judgment." Klimowicz
v. Deutsche Bank Nat'l Tr. Co., 907 F.3d 61, 66 (1st Cir. 2018)
(citation omitted).
Tyler counters that we should read the state court's
statement that her contentions did not require discussion to mean
that the state court believed that it lacked standing to entertain
her federal claims on the merits. Hence, she argues, the state
court arrived at no final judgment susceptible to challenge or
"end-run." We cannot agree. As the Appeals Court's opinion itself
notes, the 2013 SJC opinion rejecting for lack of standing Tyler's
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attempt to intervene in the criminal proceeding declared that Tyler
would have standing to assert her claims in an appeal from an order
of the Family and Probate Court. See H.T. v. Commonwealth, 989
N.E.2d at 426; H.T. v. J.M., 2016 WL 7046435, at *1 ("The [SJC]
explained . . . that it remained open to the mother to raise any
claim of error in the ordinary appellate process from proceedings
in the Probate and Family Court."). It would therefore make no
sense to interpret the Appeals Court's opinion in the appeal
arising out of the Probate and Family Court proceedings as
incorporating the SJC's standing analysis from the prior criminal
case, barring her from taking the precise action blessed by the
SJC. Besides, Tyler has given us no reason to believe that her
standing was even contested in either the Appeals Court case or
the 2017 SJC appeal. We therefore read the Appeals Court's
footnote to mean that it reached Tyler's federal constitutional
claims and summarily rejected them on their merits. So, when the
SJC declined to review the Appeals Court's decision, the statecourt system ruled finally on Tyler's constitutional claims.
This analysis also disposes of Tyler's alternative
argument: that she is not seeking a reversal of the state-court
judgment, but rather presenting an independent, "general challenge
to the constitutionality of state law." It is true that the
Rooker-Feldman doctrine does not bar a "general attack on the
constitutionality" of a state law that "do[es] not require review
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of a judicial decision in a particular case." Feldman, 460 U.S.
at 487. "'If a federal plaintiff "presents an independent claim,"'
it is not an impediment to the exercise of federal jurisdiction
that the 'same or a related question' was earlier aired between
the parties in state court." Skinner v. Switzer, 562 U.S. 521,
532 (2011) (alterations omitted) (quoting Exxon Mobil Corp., 544
U.S. at 292–93). But that exception does not apply "if the relief
sought in federal court is directed towards undoing the prior state
judgment." Maymó-Meléndez v. Álvarez-Ramírez, 364 F.3d 27, 34
(1st Cir. 2004). As we have explained, the relief Tyler seeks is
entirely predicated on her insistence that the SJC erred in the
2017 adjudication of her case. Her attempt to reframe the case as
an independent challenge to the Massachusetts law is therefore
"felled by [her] own complaint." McKenna v. Curtin, 869 F.3d 44,
48 (1st Cir. 2017).
Finally, Tyler argues that "the state proceedings have
not ended with regard to the federal issues [she] seeks to have
reviewed in federal court." See Exxon Mobil Corp., 544 U.S. at
291 (holding that the Rooker-Feldman doctrine only applies when
the losing party in state court files suit in federal court "after
the state proceedings ended"). In connection with this argument,
she observes that her family court matters "will remain pending
for at least another ten years." But she offers no suggestion
that the family court will ever reconsider the federal claims she
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presses here. See Federación de Maestros, 410 F.3d at 25
(observing that state proceedings have ended for purposes of the
Rooker-Feldman doctrine when "the state court proceedings have
finally resolved all the federal questions in the litigation, but
state law or purely factual questions . . . remain to be
litigated").
In sum, Tyler is a "losing party in state court [who]
filed suit in federal court after the state proceedings ended,
complaining of an injury caused by the state-court judgment and
seeking review and rejection of that judgment." Federación de
Maestros, 410 F.3d at 24 (quoting Exxon Mobil Corp., 544 U.S. at
291). The district court therefore correctly held that it lacked
jurisdiction to hear Tyler's claims.

Outcome: For the foregoing reasons, we affirm the district
court's dismissal for want of jurisdiction.

Plaintiff's Experts:

Defendant's Experts:

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