Jessica Jay Scott et al v. Chilton County Department of Human Resources - Dismissal Under Younger Abstention

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March 31, 2026 Get Citation Alerts Download PDF Add Note

Jessica Jay Scott, et al. v. Chilton County Department of Human Resources, et al.

District Court, M.D. Alabama

• Citations: None known
• Docket Number: 2:25-cv-00928

• Precedential Status: Unknown Status

• Opinion

• Authorities (40)

• Cited By (0)

• Summaries (0)

• Similar Cases (30K)

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Trial Court Document

IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF ALABAMA
NORTHERN DIVISION
JESSICA JAY SCOTT, et al., )
)
Plaintiffs, )
)
v. ) CASE NO. 2:25-cv-928-RAH
)
CHILTON COUNTY )
DEPARTMENT OF HUMAN )
RESOURCES, et al., )
)
Defendants. )

MEMORANDUM OPINION AND ORDER
THIS MATTER is before the Court on the Report and Recommendation (doc.
17) issued by the Magistrate Judge on March 2, 2026. In the Report, the Magistrate
Judge recommended the Court dismiss the Complaint under the domestic relations
exception to federal subject matter jurisdiction. Plaintiffs filed timely objections.
(Doc. 18.) For the reasons set forth below, the Complaint is due to be dismissed
without prejudice, albeit on different grounds than those recommended by the
Magistrate Judge.
BACKGROUND
Plaintiffs Jessica Jay Scott and John Burton Eubanks, Jr. filed this action on
November 21, 2025, against the Chilton County Department of Human Resources,
Chilton County Sheriff’s Department, Mallory Ratliff, Dayla Hamilton, Ali
Patterson, Shane Mayfield, and Judge Christopher G. Speaks. (Doc. 1.) The suit
arises out of ongoing termination of parental rights proceedings in state court. (Id.)
Defendants removed Plaintiffs’ children from their home after Plaintiffs were
criminally charged with child abuse. (Id.) After a jury trial, Plaintiffs were acquitted
of all charges; however, Defendants refused to return the children to their custody
and instead initiated termination proceedings. (Id. at 1.) Plaintiffs seek damages and
injunctive relief, including an order “preventing termination of parental rights
proceedings” and restoring their “custody rights” over their children. (Id. at 3.) The
matter was referred to the Magistrate Judge pursuant to 28 U.S.C. § 636.
On March 2, 2026, the Magistrate Judge recommended that this matter be
dismissed in its entirety for lack of subject matter jurisdiction. The Magistrate Judge
found that jurisdiction is lacking because the relief that Plaintiffs seek stems from
ongoing child removal and termination of parental rights proceedings, and those are
issues of state law, not federal law. (Doc. 17 at 2–3.) Plaintiffs filed timely
objections. They argue that federal jurisdiction is proper because they seek only
monetary and declaratory relief for past constitutional harms, not prospective
injunctive relief. (Doc. 18 at 2.)
STANDARD OF REVIEW
A district judge has broad discretion to accept, reject, or modify a magistrate
judge’s proposed findings and recommendations. United States v. Raddatz, 447 U.S.
667, 680 (1980). Under 28 U.S.C. § 636 (b)(1), the Court reviews any portion of the
Report and Recommendation that is the subject of a proper objection on a de novo
basis and any non-objected portion under a “clearly erroneous” standard. “Parties
filing objections to a magistrate’s report and recommendation must specifically
identify those findings objected to. Frivolous, conclusive or general objections need
not be considered by the district court.” Marsden v. Moore, 847 F.2d 1536, 1548
(11th Cir. 1988).
DISCUSSION
The Magistrate Judge recommended that this action be dismissed because the
domestic relations exception to federal subject matter jurisdiction foreclosed
jurisdiction over Plaintiffs’ claims. (Doc. 17 at 2–3.) For the reasons that follow, this
Court disagrees that the domestic relations exception applies across-the-board in this
matter. Nevertheless, the Court will abstain from hearing this matter under Younger
abstention.
A. Domestic Relations Exception
Federal courts are courts of limited jurisdiction. U.S. Const. art. III, § 2. As
such, federal district courts “are empowered to hear only those cases within the
judicial power of the United States as defined by Article III of the Constitution, and
which have been entrusted to them by a jurisdictional grant authorized by Congress.”
Univ. of S. Ala. v. Am. Tobacco Co., 168 F.3d 405, 409 (11th Cir. 1999). Congress
provided that federal subject matter jurisdiction extends over matters “arising under
the Constitution, laws, or treaties of the United States,” 28 U.S.C. § 1331, and
matters between citizens of different states where the amount in controversy exceeds
$75,000, 28 U.S.C. § 1332.
As the Magistrate Judge correctly noted, the Supreme Court has recognized
an exception to federal subject matter jurisdiction for domestic relations cases.
Under the domestic relations exception, federal courts must generally abstain from
deciding matters “involving the issuance of a divorce, alimony, or child custody
decree” even if subject matter jurisdiction would otherwise be proper. Ankenbrandt
v. Richards, 504 U.S. 689, 704 (1992). Courts frequently apply this domestic
relations exception to cases asserting diversity jurisdiction but have split on whether
it applies to cases arising under federal question jurisdiction. See Ingram v. Hayes, 866 F.2d 368, 370–72 (11th Cir. 1988) (per curiam). The majority of circuit courts
have held that the domestic relations exception does not apply to federal question
cases. See, e.g., Deem v. DiMella-Deem, 941 F.3d 618, 623 (2d Cir. 2019) (“That
the Court in Ankenbrandt recognized a domestic relations exception to the diversity
jurisdiction statute . . . has no bearing on whether such an exception applies in non-
diversity cases.”); Atwood v. Fort Peck Tribal Ct. Assiniboine, 513 F.3d 943, 945 (9th Cir. 2008) (“We hold that the ‘domestic relations exception’ . . . applies only to
the diversity jurisdiction statute, 28 U.S.C. § 1332. . . .”); O’Bryant v. N.J. Div. of
Child Prot. & Permanency, 818 F. App’x 143, 145 (3d Cir. 2020) (per curiam)
(same); Reale v. Wake Cnty. Hum. Servs., 480 F. App’x 195, 197 (4th Cir. 2012)
(per curiam) (same); United States v. Bailey, 115 F.3d 1222, 1231 (5th Cir. 1997)
(same); see also United Stated v. Crawford, 115 F.3d 1397, 1401–02 (8th Cir. 1997)
(noting that the Supreme Court has only applied the domestic relations exception in
diversity cases). But see Mandel v. Town of Orleans, 326 F.3d 267, 271 (1st Cir.
2003); Alexander v. Rosen, 804 F.3d 1203, 1205 (6th Cir. 2015); Syph v. Arce, 772
F. App’x 356, 357 (7th Cir. 2019) (per curiam).
Neither the Supreme Court nor the Eleventh Circuit have expressly decided
whether the exception applies to federal question cases, but the Eleventh Circuit has
noted that “the courts that liberally apply the domestic relations exception to federal
question jurisdiction” have not done so in all cases, but only “when the federal court
would necessarily become enmeshed in the domestic factual disputes.” Ingram, 866
F.2d at at 372; see also Carver v. Carver, 954 F.2d 1573, 1578 (11th Cir. 1992)
(“[T]he domestic relations exception has been applied only to diversity jurisdiction
or federal question jurisdiction which would require adjudication of domestic
affairs.”).
Here, the Court’s subject matter jurisdiction is rooted in federal question
jurisdiction because Plaintiffs assert claims pursuant to the Constitution and laws of
the United States, including 42 U.S.C. § 1983 and the First, Fourth, and Fourteenth
Amendments to the Constitution. (Doc. 1 at 2.) See 28 U.S.C. § 1331. Given the lack
of clear precedent by the Eleventh Circuit, this Court declines to extend the domestic
relations exception to this matter arising under federal question jurisdiction.
Accordingly, Plaintiffs’ objections to the Magistrate Judge’s Report are due to be
sustained to the extent they argue against application of the domestic relations
exception in this matter.
B. Younger Abstention
Although the domestic relations exception does not apply in this matter, the
Court nevertheless will abstain from hearing Plaintiffs’ claims. In the Complaint,
Plaintiffs request injunctive relief “preventing termination of parental rights
proceedings” and restoring their custody rights over their minor children.1 (Doc. 1
at 3.) Plaintiffs also seek damages related to alleged constitutional violations in the
course of the ongoing proceedings. Because such relief would interfere with ongoing
state civil enforcement proceedings,2 Younger abstention is proper, and the
Complaint is due to be dismissed without prejudice.
The Supreme Court has made clear that Younger abstention is limited to three
“exceptional” categories: (1) “state criminal prosecutions[,]” (2) “civil enforcement
proceedings[,]” and (3) “civil proceedings involving certain orders that are uniquely
in furtherance of the state courts’ ability to perform their judicial functions.” Sprint
Commc’ns Inc. v. Jacobs, 571 U.S. 69, 77 (2013) (quoting New Orleans Pub. Serv.,
Inc. v. Council of City of New Orleans, 491 U.S. 350, 367–68 (1989)). At issue here
is the exact type of civil enforcement for which Younger has been extended to cover,

1 In their objections, Plaintiffs appear to attempt to amend the complaint and disclaim any request
for injunctive relief related to the ongoing state proceedings. But when “a request for leave to file
an amended complaint simply is imbedded within an opposition memorandum, the issue has not
been raised properly.” Newton v. Duke Energy Fla., LLC, 895 F.3d 1270, 1277 (11th Cir. 2018).
Therefore, the Court will only consider the relief requested in the operative complaint, which
includes a request for injunctive relief.

2 According to the notice filed by Plaintiffs, termination proceedings were scheduled for February
18, 2026. (Doc. 15.) For the purposes of this Order, the Court assumes that the proceedings in state
court remain ongoing. Even if the proceedings have concluded, abstention from hearing Plaintiffs’
claims for injunctive relief would be proper under Rooker–Feldman. See, e.g., Liedel v. Juv. Ct. of
Madison Cnty., 891 F.2d 1542, 1544–46 (11th Cir. 1990) (holding that complaint must be
dismissed under Rooker–Feldman where relief would “effectively nullify . . . state orders”).
e.g., child protection and child custody proceedings. See Moore v. Sims, 442 U.S.
415, 419–20 (1979) (extending Younger to state-initiated proceeding to gain custody
of children allegedly abused by their parents).
Younger abstention bars federal court intervention in “ongoing state judicial
proceeding[s]” where “the proceedings implicate important state interests[] and
there is an adequate opportunity in the state proceedings to raise constitutional
challenges.” Adams v. Florida, 185 F. App’x 816, 816–17 (11th Cir. 2006) (per
curiam). To determine whether the federal proceeding would interfere with the state
one, courts “look to the relief requested and the effect it would have on the state
proceedings.” 31 Foster Children v. Bush, 329 F.3d 1255, 1276 (11th Cir. 2003).
The plaintiff bears the burden of establishing that the state proceedings do not
provide an adequate remedy for their federal claims. Butler v. Ala. Jud. Inquiry
Comm’n, 261 F.3d 1154, 1159 (11th Cir. 2001). A federal court “should assume that
state procedures will afford an adequate remedy, in the absence of unambiguous
authority to the contrary.” Pennzoil Co. v. Texaco, Inc., 481 U.S. 1, 15 (1987).
Younger abstention is proper in this case because the requested injunctive
relief would interfere with important state interests and Plaintiffs have not
demonstrated that they lack the ability to raise their arguments in the ongoing state
proceedings. Courts have long recognized that states have important interests in
child welfare and child protection. See, e.g., Santosky v. Kramer, 455 U.S. 745, 766 (1982) (recognizing state’s interest in “preserving and promoting the welfare of the
child”); Doe v. Kearney, 329 F.3d 1286, 1293 (11th Cir. 2003) (recognizing that the
state has a “profound interest in the welfare” of children (quoting Tenenbaum v.
Williams, 193 F.3d 581, 592 (2d Cir. 1999))). The injunctive relief sought would
directly interfere with the state proceedings because Plaintiffs seek an order halting
the proceedings and preventing the state court from terminating their parental rights.
See Bush, 329 F.3d at 1276–79 (analyzing whether the requested relief sought to
control or prevent the occurrence of specific events that might take place in the
ongoing state proceedings).
Moreover, Plaintiffs have not shown that they lack an adequate opportunity to
raise their federal claims in state court. Plaintiffs argue that federal relief is warranted
because Defendants plan to introduce inaccurate, inconsistent, and misleading
evidence at the termination trial that is inconsistent with physical evidence and
witness testimony. But they have not demonstrated that they cannot adequately raise
these concerns in state court. Alabama law requires courts to consider the best
interest of the children before granting a petition to terminate parental rights. Ala.
Code § 12-15-319. Among the nonexclusive factors are whether a parent has abused
or otherwise maltreated the children and whether a parent has been convicted of and
imprisoned for a felony. See Ala. Code § 12-15-319 (a)(3)–(4). Thus, Plaintiffs may
present evidence of their acquittal of child abuse charges as well as any other
evidence to dispute Defendants’ evidence. Accordingly, Plaintiffs’ claims for
injunctive relief are due to be dismissed.
Moreover, Plaintiffs’ claims for damages are also due to be dismissed.
Although not yet decided by the Supreme Court, the Eleventh Circuit has indicated
that Younger abstention extends to cases involving § 1983 claims for monetary
damages where the ongoing state proceeding implicates an important state interest,
the state proceeding will provide an adequate remedy for the federal claims, and the
federal proceeding would interfere with the underlying state case. See Doby v.
Strength, 758 F.2d 1405, 1406 (11th Cir. 1985); Prather v. Norman, 901 F.2d 915,
919 (11th Cir. 1990) (citing Deakins v. Monaghan, 484 U.S. 193, 202 (1988)
(reserving the issue as to whether Younger applies to § 1983 damages actions))
(requiring abstention pursuant to Younger where plaintiff raised Fourth Amendment
§ 1983 damages claims related to ongoing state criminal proceedings); Stoddard v.
Fla. Bd. of Bar Exam’rs, 509 F. Supp. 2d 1117 (N.D. Fla. 2006), aff’d, 229 F. App’x
911 (11th Cir. 2007). Here, as discussed above, Plaintiffs have not demonstrated that
the state court cannot address the alleged constitutional violations that form the basis
of their damage claims. And any adjudication of the constitutional adequacy of the
process provided to Plaintiffs in the ongoing termination proceedings would unduly
interfere with the state court’s resolution of the underlying matter. See Jones v.
Takaki, No. 92 C 7076, 1993 WL 41420, at *3 (N.D. Ill. Feb. 18, 1993) (“Most
significantly, given the doctrine of res judicata, the basic policy against federal
interference with pending state criminal prosecutions generally will be frustrated as
much by a damages award as it would be by either declaratory relief or an
injunction.”).
Accordingly, Plaintiffs’ remaining claims for damages are due to be
dismissed3 without prejudice.4 See Boyd v. Georgia, 512 F. App’x 915, 918 (11th
Cir. 2013) (affirming district court’s dismissal of § 1983 damages claim on Younger
abstention grounds); Jones, 1993 WL 41420, at *3 (dismissing § 1983 claim under

3 Although the Supreme Court advised in Quackenbush that federal courts abstaining from
deciding a § 1983 damages claim under Younger should ordinarily stay rather than dismiss the
action, the Court declines to issue a stay because Plaintiffs seek primarily equitable relief and their
claims arise under federal question jurisdiction, not diversity jurisdiction as was the case in
Quackenbush. See Ford v. Tait, 163 F. Supp. 2d 57, 67 (D.D.C. 2001) (dismissing § 1983 damages
claim under Younger because claim arose under federal question jurisdiction and plaintiff
primarily sought equitable relief); Stein v. Legal Advert. Comm. of Discipline Bd., 272 F. Supp. 2d
1260, 1275 (D.N.M. 2003) (same); Discovery House, Inc. v. Consol. City of Indianapolis, 970 F.
Supp. 655, 660–61 (S.D. Ind. 1997) (same); see also Wideman v. Colorado, 242 F. App’x 611,
(10th Cir. 2007) (upholding dismissal of § 1983 damages claims over state child custody
proceedings).

4 Since dismissal is without prejudice, Plaintiffs may refile their damage claims once the
termination proceedings have concluded. The Court also notes that dismissal of this action for
claimed damages arising out of an ongoing legal proceeding is appropriate on ripeness grounds
because the state proceedings have not yet concluded. See McKinney v. Pate, 20 F.3d 1550, 1560 (11th Cir. 1994) (holding that “no procedural due process right has been violated unless and until
the state fails to remedy” the alleged inadequacy in the process provided); Stubbs v. City of Ctr.
Point, 988 F. Supp. 2d 1270, 1280 (N.D. Ala. 2013) (dismissing § 1983 procedural due process
claim on ripeness grounds due to ongoing state proceedings).
Younger abstention with leave to reinstate upon conclusion of the underlying state
criminal proceeding).
C. Shotgun Complaint
Although not addressed by the Magistrate Judge, the Complaint is also due to
be dismissed because it is a classic shotgun pleading. “The unifying characteristic of
all types of shotgun pleadings is that they fail to one degree or another, and in one
way or another, to give the defendants adequate notice of the claims against them
and the grounds upon which each claim rests.” Weiland v. Palm Beach Cnty.
Sheriff’s Off., 792 F.3d 1313, 1323 (11th Cir. 2015). The Eleventh Circuit has
identified four characteristics of classic shotgun pleadings. These are pleadings that:
(1) contain multiple counts where each adopts the allegations of all
preceding counts; (2) are filled with conclusory, vague, and immaterial
facts not obviously connected to any particular cause of action; (3) do
not separate each cause of action or claim into separate counts; or (4)
assert multiple claims against multiple defendants but do not specify
which defendant is responsible for which acts or omissions.
Brown v. Air Line Pilots Ass’n, 813 F. App’x 353, 355 (11th Cir. 2020) (cleaned up).
Here, the Complaint exhibits at least two characteristics of shotgun pleadings.
First, each count contains conclusory assertions without stating the factual basis for
the alleged constitutional violation. For example, the entirety of Count II summarily
states that “Defendants deprived Plaintiffs of constitutionally required notice, fair
hearings, accurate evidence, and opportunities for reunification.” (Doc. 1 at 2.)
Count III states that “Defendants interfered with Plaintiffs’ fundamental right to
family integrity without compelling justification.” (Id.) Rule 8(a) requires more than
these broad and conclusory statements unconnected to any concrete facts. See
Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (“[A] complaint [does not] suffice if it
tenders ‘naked assertion[s]’ devoid of ‘further factual enhancement.’” (quoting Bell
Atl. Corp. v. Twombly, 550 U.S. 544, 557 (2007))).
Second, the Complaint does not specify which of the Defendants are
responsible for which actions—it broadly alleges that all of the “Defendants”
undertook identical acts or omissions. This, too, is insufficient to provide Defendants
with notice of the factual basis for the claims against them. See, e.g., Magluta v.
Samples, 256 F.3d 1282, 1284 (11th Cir. 2001) (“The complaint is replete with
allegations that ‘the defendants’ engaged in certain conduct, making no distinction
among the fourteen defendants charged, though geographic and temporal realities
make plain that all of the defendants could not have participated in every act
complained of.”); Jackson v. Bank of Am., N.A., 898 F.3d 1348, 1357 (11th Cir.
2018) (holding that complaint was a shotgun pleading where it incorporated by
reference all factual allegations into each claim and “ma[de] it nearly impossible for
Defendants and the Court to determine with any certainty which factual allegations
g[ave] rise to which claims for relief”).
Therefore, the Complaint is also due to dismissed as a shotgun complaint.
Although courts “should freely give leave when justice so requires,” Fed. R. Civ. P.
15(a)(2), Plaintiffs will not be given leave to amend because any proposed amended
complaint would also be subject to dismissal under Younger for the reasons
discussed above.
CONCLUSION
Accordingly, it is ORDERED as follows:
(1) Plaintiffs’ Objections (doc. 18) to the Magistrate Judge’s Report and
Recommendation (doc. 17) are SUSTAINED in part, and
OVERRULED in part;
(2) The Magistrate Judge’s Report and Recommendation (doc. 17) is
ADOPTED in part and REJECTED in part; and
(3) The Complaint (doc. 1) is DISMISSED without prejudice; and
(4) The Clerk of Court is directed to close this matter.
DONE and ORDERED on this the 31st day of March 2026.

R. hie JR.
CHIEF ED STATES DISTRICT JUDGE

11