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CASPER III v. Alan P. Krasnoff, Clerk of Court, Defendant. (2021)

United States Court of Appeals, Fourth Circuit.2021-03-29No. No. 20-7672

Summary

Holding. The appellate court affirmed the district court's dismissal of Casper's complaint, finding no reversible error in the lower court's reasoning that Casper failed to show an injury from denied access to courts and that claims challenging state appellate decisions are barred by the Rooker-Feldman doctrine.

Willie Lee Casper III appealed a district court order that dismissed his federal civil rights lawsuit under screening requirements for in-forma pauperis filings. Casper's complaint alleged that he was denied access to the courts, but the district court found he could not demonstrate any actual injury because the legal issues he wanted to raise had already been addressed and rejected in previous cases. Additionally, to the extent Casper sought to challenge the Virginia Supreme Court's decision to deny his appeal regarding a circuit court order, the district court properly applied the Rooker-Feldman doctrine, which prevents lower federal courts from reviewing final state court judgments on appeal.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether dismissal under screening standards for in-forma pauperis filings was proper
  • Whether plaintiff demonstrated injury from alleged denial of access to courts
  • Whether Rooker-Feldman doctrine bars review of state court decisions

Procedural posture

Casper appealed the district court's dismissal of his civil rights complaint filed in federal court.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

Willie Lee Casper, III, appeals the district courts order dismissing his 42 U.S.C. § 1983 complaint under 28 U.S.C. § 1915A(b). We have reviewed the record and find no reversible error.

Caspers amended complaint, in essence, alleged denial of access to courts. However, Casper could not show an injury for any purported denial of access, because the issues he sought to pursue had already been raised and rejected in prior actions. To the extent that Casper sought to challenge the Supreme Court of Virginias denial of his appeal of the circuit courts order denying his 2019 motion to vacate, we conclude that the district court correctly held that such a claim is barred by the Rooker-Feldman 1

doctrine. See Thana v. Bd. of License Commrs, 827 F.3d 314, 318-19 (4th Cir. 2016) (explaining that doctrine provides “that lower federal courts are precluded from exercising appellate jurisdiction over final state-court judgments” (internal quotation marks omitted)). Accordingly, we affirm for the reasons stated by the district court.

2

Casper v. Robelen, No. 1:20-cv-00802-LO-TCB (E.D. Va. filed Oct. 24, 2020 & entered Oct. 27, 2020). We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before this court and argument would not aid the decisional process.

AFFIRMED

FOOTNOTES

1

.   D.C. Court of Appeals v. Feldman, 460 U.S. 462, 103 S.Ct. 1303, 75 L.Ed.2d 206 (1983); Rooker v. Fid. Tr. Co., 263 U.S. 413, 44 S.Ct. 149, 68 L.Ed. 362 (1923).

2

.   We decline to consider claims that Casper raises for the first time on appeal. See Pornomo v. United States, 814 F.3d 681, 686 (4th Cir. 2016).

PER CURIAM:

Affirmed by unpublished per curiam opinion.

Unpublished opinions are not binding precedent in this circuit.