A D.C. federal court dismissed a grandmother's pro se complaint tied to an Illinois child custody matter, saying the dispute belonged in state court.
What happened
A D.C. federal judge dismissed without prejudice a pro se complaint brought by Michele Partl-Brown over an Illinois child custody dispute, while granting her request to proceed without paying court fees.
The opinion says Partl-Brown's complaint appeared to stem from an Illinois Department of Children and Family Services investigation after which her grandchildren were removed from her home and placed with their father. The court said it presumed she sought the children's return to her home and her daughter's custody, although the complaint did not demand particular relief.
U.S. District Judge Randolph D. Moss said the case ran into the long-standing limits on federal court involvement in domestic relations matters. Federal courts generally decline to intervene in family-law disputes, the opinion said, because it is "appropriate for federal courts to leave delicate issues of domestic relations to the state courts."
The court acknowledged that the complaint invoked due process, but found that was not enough on its own to turn the custody dispute into a federal case. The opinion said the complaint offered little or no explanation of how the state violated Partl-Brown's or her daughter's procedural due process rights.
Judge Moss also identified separate defects. To the extent Partl-Brown wanted the D.C. court to review, revise or overturn an Illinois court ruling, the court said it lacked jurisdiction to do so. And even apart from jurisdiction, the complaint was too vague and conclusory to state a claim and did not show enough basis to infer standing to challenge the denial of custody to Partl-Brown's daughter.
The dismissal was without prejudice, and the court said a separate order would issue.