United States District Court, E.D. California
WILLIAM J. LAWS, Plaintiff,
CAROLYN LAWS, Defendant.
ALLISON CLAIRE, UNITED STATES MAGISTRATE JUDGE
case is before the undersigned by consent of the parties
pursuant to 28 U.S.C. 636(c)(1). See ECF No. 31.
This is one of two cases in which plaintiff William J. Laws
has sought the intervention of the district court in a
pending Solano County probate proceeding. In the probate
matter, Solano Superior Court Case No. FPR 045231, plaintiff
was removed by the court as trustee of his late mother's
trust, following a finding that he had breached his fiduciary
duty; Carolyn Laws, the wife of plaintiff's late brother
and nominal defendant here, was appointed trustee; and title
to certain residential property was ordered transferred from
plaintiff to the trust. In Laws v. Laws, Case No.
2:17-cv-00525 JAM CKD, petitioner purported to
“remove” the Solano County matter to federal
court. That case was dismissed sua sponte for lack of
jurisdiction. Id. at ECF Nos. 3, 13. The instant
case, which also seeks relief from the probate court's
jurisdiction and orders, was commenced on February 21, 2017,
with the filing of a “Complaint and Request for
Injunction and for Conversion of Property and for an
Adjudication of the Trust.” ECF No. 1.
courts are courts of limited jurisdiction, and may adjudicate
only those cases authorized by federal law. Kokkonen v.
Guardian Life Ins. Co., 511 U.S. 375, 377 (1994);
Willy v. Coastal Corp., 503 U.S. 131, 136-37 (1992).
“Federal courts are presumed to lack jurisdiction,
‘unless the contrary appears affirmatively from the
record.'” Casey v. Lewis, 4 F.3d 1516,
1519 (9th Cir. 1993) (quoting Bender v. Williamsport Area
Sch. Dist., 475 U.S. 534, 546 (1986)). A federal court
“ha[s] an independent obligation to address sua sponte
whether [it] has subject-matter jurisdiction.”
Dittman v. California, 191 F.3d 1020, 1025 (9th Cir.
1999). Without jurisdiction, the district court cannot decide
the merits of a case or order any relief. See Morongo
Band of Mission Indians v. Cal. State Bd. of
Equalization, 858 F.2d 1376, 1380 (9th Cir. 1988).
readily apparent that the district court lacks jurisdiction
over this dispute. Probate and trust administration are
governed by state law and fall within the exclusive
jurisdiction of the state courts. The United States Supreme
Court has long recognized that the federal courts have no
jurisdiction over probate matters, and may not directly
interfere with probate proceedings. Markham v.
Allen, 326 U.S. 490, 494 (1946). The “probate
exception” recognized in Markhan reserves to
state courts the probate of wills and administration of
decedent's estates. Marshall v. Marshall, 547
U.S. 293, 311 (2006). The instant lawsuit expressly seeks
federal court exercise of jurisdiction over state probate
proceedings and trust administration. Accordingly, the
complaint must be dismissed sua sponte for lack of
alternative, the complaint must be dismissed on grounds that
it is so patently meritless that it cannot confer subject
matter jurisdiction. See Hagans v. Lavine, 415 U.S.
528, 543 (1974) (a claim may be dismissed for lack of
jurisdiction if it is “so insubstantial, implausible, .
. . or otherwise completely devoid of merit as not to involve
a federal controversy within the jurisdiction of the District
Court”); Bell v. Hood, 327 U.S. 678 (1946)
(recognizing that a claim is subject to dismissal for want of
jurisdiction where it is “wholly insubstantial and
frivolous” and so patently without merit as to justify
dismissal for lack of jurisdiction); Franklin v.
Murphy, 745 F.2d 1221, 1227 n.6 (9th Cir. 1984) (holding
that even “[a] paid complaint that is ‘obviously
frivolous' does not confer federal subject matter
jurisdiction . . . and may be dismissed sua sponte. .
.”). The complaint here is frivolous because, for
several reasons, no relief is legally possible in federal
extent that plaintiff seeks injunctive relief
vis-à-vis a pending state court proceeding, such
relief is barred by the Anti-Injunction Act. See 18
U.S.C. § 2283; Lou v. Belzberg, 834 F.2d 730,
739 (9th Cir. 1987).
extent that plaintiff seeks in effect, even if not in form,
to enjoin or impede the ongoing probate proceeding, federal
court interference is forbidden by Younger v.
Harris, 401 U.S. 37, 45 (1971) and progeny. See
Middlesex County Ethics Committee v. Garden State Bar
Ass'n, 457 U.S. 423, 432 (1982) (federal courts must
abstain from interference in state court civil proceedings
that (1) are ongoing; (2) implicate “important state
interests”; and (3) provide an adequate opportunity to
raise federal questions); see also Gilbertson v.
Albright, 381 F.3d 965, 978 (9th Cir. 2004) (en banc)
(recognizing implied fourth requirement that the federal
court action would “enjoin the proceeding, or have the
practical effect of doing so.”).
extent that plaintiff seeks to set aside the final judgment
of a state court, his claims are outside the scope of federal
jurisdiction independently of the probate exception. See
District of Columbia Court of Appeals v. Feldman, 460
U.S. 462, 476 (1983); Rooker v. Fidelity Trust Co.,
263 U.S. 413, 415 (1923); see also Branson v. Nott,
62 F.3d 287, 291-92 (9th Cir. 1995). Relief from state court
error comes through the state appellate courts, not through
the lower federal courts. See Chick Kam Soo v. Exxon
Corp., 486 U.S. 140, 146 (1988).
the court notes that although Carolyn Laws is the only
remaining named defendant, plaintiff alleges that his rights
were violated by the state court. Id. at 7.
There is no legal theory under which Carolyn Laws could be
liable for any deprivation of plaintiff's rights in or by
the state court in its exercise of its judicial function.
There are no different or additional facts, given the nature
of the dispute, which could support a viable cause of action
against Carolyn Laws or anyone else involved in the probate
dispute. Accordingly, the complaint is frivolous as a matter
of law and cannot be cured by amendment. The gravamen of this
dispute is the substance of the probate proceeding, over
which this court cannot exercise jurisdiction for the reasons
the court lacks subject matter jurisdiction both because the
complaint is frivolous and pursuant to the ...