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ELEVENTH CIRCUIT REVERSES DISTRICT COURT DISMISSAL OF FEDERAL CLAIMS ARISING FROM STATE CUSTODY CASE


In Behr v. Campbell, the United States Court of Appeals for the Eleventh Circuit provided guidance regarding the proper application of the Rooker-Feldman doctrine, which bars appeals of state court judgments to federal district courts. The plaintiffs, a father and two of his children, filed suit in the United States District Court for the Southern District of Florida alleging both federal and state law claims against his ex-wife, the Palm Beach County School District, the Palm Beach County Department of Children and Families, and various other defendants. Because the claims were related to a state custody action, the district court dismissed the entire complaint with prejudice under the Rooker-Feldman doctrine. On appeal, the Eleventh Circuit reversed the district court’s decision, holding that three of the plaintiffs’ claims should not have been dismissed because they were not appeals of state court judgments.



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