United States Tenth Circuit

In a civil rights action brought by a child and parents arising from the child's life threatening illness against defendants who were involved in a legal dispute in a Utah juvenile court over the child's custody and medical care (parents refused to obtain chemotherapy treatment for child), summary judgment for defendants is affirmed in part where: 1) a lower federal court would necessarily have to review and reject certain state-court judgments in order for plaintiffs to succeed on their malicious prosecution claims; 2) defendant-prosecutor's representations in a state court proceeding were intimately associated with the judicial process and her role as an advocate for the state; 3) plaintiffs' right to direct their son's medical care in this case -- if any right indeed exists in such circumstances -- was not clearly established at the time they alleged the right was violated; and 4) plaintiffs failed to show that any defendant imposed an undue burden on their relationship with the child and therefore failed to show a violation of their associational rights. However, the judgment is reversed in part where plaintiffs' malicious prosecution claims necessarily invite federal-court undoing of two adverse state-court orders, and thus the Rooker-Feldman doctrine bars such claims.

Appellate Information

• Decided 05/05/2010
• Published 05/05/2010

Judges

Court

• United States Tenth Circuit

Counsel