United States District Court, S.D. Indiana, Indianapolis Division
RICHARD E. MAUL, Plaintiff,
CYNDIE RN, JOSE P BHRA, DR YOUNG R MD, Defendants.
ORDER GRANTING MOTION TO DISMISS
PATRICK HANLON UNITED STATES DISTRICT JUDGE
Richard Maul, alleges that Defendants violated his
constitutional rights by forcing him to take medicine against
his will. Defendants have moved to dismiss the case on the
basis that the Court lacks jurisdiction. Because a state
court previously ordered Mr. Maul to take medications as
prescribed, his claim is essentially an appeal of that
state-court judgment. Federal district courts do not have
jurisdiction over appeals from state-court judgments, so the
Court grants the motion to dismiss and dismisses the case for
lack of jurisdiction. Dkt. ; dkt. .
Facts and Background
Maul is a patient at Richmond State Hospital. Dkt. 1. He was
involuntarily committed to the hospital in November 2016,
after the Henry County Circuit Court found that he was
mentally ill “due to a psychiatric disorder that
substantially disturbs his thinking, feeling, and
behavior.” Dkt. 21-1. The court also found that there
was a substantial risk that Mr. Maul would hurt himself or
others and committed him to the hospital with the condition
that he take prescribed medications. Id. In November
2018, the court reviewed the case and entered an order
continuing the Mr. Maul's commitment (collectively, the
“Commitment Order”). Dkt. 21-2.
Maul sued Doctor Young, Doctor Pearson, and Nurse Gates under
42 U.S.C. § 1983 for violating his constitutional
rights. Dkt. 1; dkt. 16; dkt. 18. According to Mr. Maul,
Defendants gave him shots of Risperdal and another substance
against his will. Dkt. 1 at 2. He complains that Defendants
consider him dangerous to himself and others despite the fact
that he has not “done anything wrong.”
Id. Defendants moved to dismiss Mr. Maul's
complaint, dkt. 19, dkt. 38, and Mr. Maul has not responded
to either motion.
have moved to dismiss the case under Federal Rule of Civil
Procedure 12(b)(1) for lack of subject-matter jurisdiction.
When ruling on a 12(b)(1) motion to dismiss, the court must
accept as true all well-pleaded factual allegations and draw
reasonable inferences in favor of the plaintiff. Ezekiel
v. Michel, 66 F.3d 894, 897 (7th Cir. 1995). In
addition, the Court “may properly look beyond the
jurisdictional allegations of the complaint and view whatever
evidence has been submitted on the issue to determine whether
in fact subject matter jurisdiction exists.”
Capitol Leasing Co. v. FDIC, 999 F.2d 188, 191 (7th
Cir. 1993) (per curiam).
Mr. Maul is a pro se plaintiff, the Court construes
his complaint liberally and holds it to a less stringent
standard than pleadings drafted by lawyers. Erickson v.
Pardus, 551 U.S. 89, 94 (2007).
Maul alleges that when Defendants forced him to take medicine
against his will, they violated his rights under the Due
Process Clause of the Fourteenth Amendment. Washington v.
Harper, 494 U.S. 210, 222 (1990) (holding that prisoners
cannot be forcibly medicated without due process). Defendants
argue that the Court does not have jurisdiction because
adjudication of Mr. Maul's complaint would require the
Court to review the merits of a state-court decision-which is
prohibited by the Rooker-Feldman doctrine.
the Rooker-Feldman doctrine, lower federal courts do
not have jurisdiction over cases “brought by state
court losers challenging state court judgments rendered
before the district court proceedings commenced.”
Sykes v. Cook Cty. Circuit Court Prob. Div., 837
F.3d 736, 741 (7th Cir. 2016). In short, lower federal courts
do not have appellate jurisdiction over state courts.
Mains v. Citibank, N.A., 852 F.3d 669, 675 (7th
Cir.), cert. denied, 138 S.Ct. 227 (2017).
deciding if the Rooker-Feldman doctrine applies, the
court asks if the plaintiff “seeks to set aside a state
court judgment or whether he is, in fact, presenting an
independent claim.” Jakupovic v. Curran, 850
F.3d 898, 902 (7th Cir. 2017) (citation and internal quote
marks omitted). If the claim seeks to set aside a state-court
judgment, it is barred without further analysis. Id.
But even if a claim does not purport to directly appeal a
state-court decision, it is barred under the
Rooker-Feldman doctrine if it is “inextricably
intertwined” with the state-court judgment.
phrase ‘“inextricably intertwined' is a
somewhat metaphysical concept, ” but at its core, it
applies when adjudicating a claim would require a court to
review the merits of a state-court decision. Taylor v.
Fed. Nat. Mortg. Ass'n, 374 F.3d 529, 533 (7th Cir.
2004) (quotation and citation omitted). If the plaintiff
would have no claim “but for” the adverse
state-court judgment, it is intertwined with that judgment.
Ritter v. Ross, 992 F.2d 750, 754-55 (7th Cir.
1993). If the claim is intertwined with a state-court
judgment, then the court must consider if the plaintiff had a
reasonable opportunity to raise the issue in the state-court
proceeding. Brokaw v. Weaver, 305 F.3d 660, 668 (7th
Cir. 2002). If so, the court lacks jurisdiction under the
Rooker-Feldman doctrine. Taylor, 374 F.3d
when a forced-medication claim is inextricably intertwined
with a state-court judgment turns on whether the complaint
alleges a procedural or substantive deficiency in the state
court's order. See Young v. Murphy, 90 F.3d
1225, 1231 (7th Cir. 1996). A claim that challenges the
procedure a court followed in its order is not foreclosed by
the Rooker-Feldman doctrine. For example, in
Johnson v. Tinwalla, 855 F.3d 747, 749 (7th Cir.
2017), the court held that the plaintiff alleged a viable
forced-medication claim after finding that the defendant
“didn't follow Illinois's procedure for
ordering forced medication.” Since a forced-medication
claim is premised on the Due Process Clause of the Fourteenth
Amendment, federal courts have jurisdiction to consider
whether a defendant's process for requiring a
plaintiff's forced medication ...