Watkins v. Mitchem et al
MEMORANDUM OPINION. Signed by Judge L Scott Coogler on 7/6/12. (KGE, )
2012 Jul-06 AM 10:51
U.S. DISTRICT COURT
N.D. OF ALABAMA
IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ALABAMA
WARDEN BILLY MITCHEM, et al.,
) Case No. 5:11-cv-01528-LSC-TMP
MEMORANDUM OF OPINION
The magistrate judge filed a report and recommendation on May 31, 2012,
recommending that this action filed pursuant to 42 U.S.C. § 1983 be dismissed under
28 U.S.C. § 1915A(b) as frivolous on the basis of res judicata. (Doc. 9.) Plaintiff
filed objections to the report and recommendation on June 15, 2012. (Doc. 10.)
Plaintiff argues in his objections that: (1) this action is not barred by res judicata; (2)
the Rooker-Feldman doctrine applies to preclude dismissal of his case; and (3) the
court may exercise supplemental jurisdiction over his claims. (Doc. 10.)
Res judicata bars relitigation of all matters decided in a prior proceeding if:
“(1) the prior decision was rendered by a court of competent jurisdiction; (2) there
was a final judgment on the merits; (3) the parties were identical in both suits; and (4)
the prior and present causes of action are the same.” See Jang v. United Tech. Corp.,
206 F.3d 1147, 1149 (11th Cir. 2000) (quoting Israel Discount Bank, Ltd. v. Entin,
951 F.2d 311, 314 (11th Cir. 1992)). Plaintiff previously filed suit in state court
against Defendants Mitchem, Wallace, and Halbrooks for denial of due process and
equal protection with regard to his placement in administrative segregation (Compl.
at 4-5).1 Additionally, the action resulted in a final judgment against plaintiff on the
merits. Id. Despite plaintiff’s arguments to the contrary, res judicata bars his due
process and equal protection claims against Mitchem, Wallace, and Halbrooks
because the same claims against the same defendants were litigated in state court as
are now asserted in this court.
Plaintiff further argues that the Rooker-Feldman doctrine applies to preclude
dismissal of his case. Plaintiff misinterprets this doctrine. “The Rooker-Feldman
doctrine prevents lower federal courts from exercising jurisdiction over cases brought
by ‘state-court losers’ challenging ‘state-court judgments rendered before the district
court proceedings commenced.’” Lance v. Dennis, 546 U.S. 459, 460 (2006) (quoting
Exxon Mobil Corp. v. Saudi Basic Industries Corp., 544 U.S. 280, 284 (2005)).
Therefore, if the Rooker-Feldman doctrine applies, as plaintiff contends, his action
would be subject to dismissal for this court’s lack of subject matter jurisdiction.2
The court also takes judicial notice of Watkins v. Mitchem, 50 So. 3d 485 (Ala. Civ.
Plaintiff now claims in his objections that he does not wish to relitigate his claims
in federal court but rather requests “federal review of the state court proceedings for error.” (Doc.
10 at 3.) Such review is exactly what Rooker-Feldman prohibits. See Casale v. Tillman, 558 F.3d
Lastly, plaintiff contends that this court can exercise supplemental jurisdiction
over his constitutional claims. However, plaintiff misunderstands the concept of
supplemental jurisdiction. If a federal court has subject matter jurisdiction over a
party’s constitutional claims, it may exercise supplemental jurisdiction to also
consider any state law claims brought in the same action. However, plaintiff does not
purport to bring state law claims against the defendants. Even if he did, such claims
would be subject to dismissal once his constitutional claims are dismissed.
Having carefully reviewed and considered de novo all the materials in the court
file, including the report and recommendation and the objections thereto, the Court
is of the opinion that the magistrate judge's report is due to be and is hereby
ADOPTED and the recommendation is ACCEPTED. Accordingly, the complaint is
due to be dismissed pursuant to 28 U.S.C. § 1915A(b) as frivolous. A Final Judgment
will be entered.
Done this 6th day of July 2012.
L. Scott Coogler
United States District Judge
1258, 1261 (11th Cir. 2009) (“The Rooker-Feldman doctrine makes clear that federal district courts
cannot review state court final judgments because that task is reserved for state appellate courts or,
as a last resort, the United States Supreme Court.”).
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