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When a federal court case is intimately linked to a prior state case decision, the federal case runs the risk of being dismissed, New Jersey family lawyers report, according to state precedents regarding “inextricably intertwined” cases and complications. But recently, the U.S. Court of Appeals for the Third Circuit determined that a federal case involving parental custody and rights was dismissed wrongly based on this precedent. This decision further clarifies how courts should determine whether to dismiss a linked case.
When Dennis Mazzetti’s son, D.M., was born in 2007, both the baby and his mother, C.M., tested positive for cocaine. As a result, C.M. voluntarily gave up her maternal rights to the baby, but Mazzetti went into a court battle with the New Jersey Division of Child Protection and Permanency (DCPP), who sued to terminate his paternal rights. His rights were terminated after a five-day trial, and his mother Linda, the child’s grandmother, was granted custody. On appeal in 2012, the Appellate Division upheld the termination.
When D.M. was born, his mother was married to—but separated from—Mazzetti’s identical twin brother, and she told the courts she had been in a relationship with Mazzetti at the time. Although Mazzetti is listed as the father on D.M.’s birth certificate, a DNA test to confirm that paternity was inconclusive. State officials did not believe that D.M. was the real father, and used this as support for their custody termination suit. Mazzetti also refused to take several drug tests, claiming that he was unable to provide a urine sample due to a medication he was taking.
In 2012, Mazzetti filed a federal lawsuit, claiming that the DCPP moved his son from his care in violation of his rights as father. According to the suit, he was not granted a hearing, or due process, and his right to be a father was taken away. He asked for a widespread retraining of DCPP employees, as well as compensatory damages of $10 million and punitive damages of $50 million. He did not ask the courts to restore his parental rights.
The U.S. District Court in Newark dismissed the case, exercising the Rooker-Feldman rule. The Rooker-Feldman rule states that a district court cannot exercise jurisdiction over a case brought by a person who has lost a state court proceeding, and who now wants the federal court to review the state court decision. But New Jersey family lawyers say that the U.S. Court of Appeals later determined this to be an incorrect application of the rule. The district court judge who dismissed Mazzetti’s case failed to gauge the lawsuit against the Great Western Mining v. Fox Rothschild precedent, a 2010 case in the Third Circuit in which the determination warns judges against using the “inextricably intertwined” standard for dismissing cases.
At New Jersey law firm Helmer, Conley, and Kasselman, PA, we represent people who have lost their parental rights unjustly, or who have complaints against the handling of their case, either by the state or federal courts. If you have a question regarding your rights, contact an HCK family lawyer for a free, no-strings consultation today.
