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Maul v. Cyndie RN

United States District Court, S.D. Indiana, Indianapolis Division

June 25, 2019

RICHARD E. MAUL, Plaintiff,



         Plaintiff, 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. [19]; dkt. [38].

         I. Facts and Background

         Mr. 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.

         Mr. 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.

         II. Applicable Law

         Defendants 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).

         Since 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).

         III. Analysis

         Mr. 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.

         Under 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).

         When 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. Id.

         The 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 at 533.

         Determining 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 ...

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