Renee Marie Johnson, proceeding pro se, sued several defendants including state Judge Matthew Antkoviak, family members, and county social services officials after a Michigan state court removed her daughter from her custody and restricted her to supervised visitation.
Johnson filed four claims under 42 U.S.C. § 1983, alleging violations of her due process rights in the custody proceedings, as well as state law claims for malicious prosecution, abuse of process, and conspiracy against family members. The district court dismissed the entire complaint for lack of subject-matter jurisdiction under the domestic-relations exception after screening the case.
The Sixth Circuit explained that the domestic-relations exception prevents federal courts from issuing divorce, alimony, or child custody decrees, but does not bar federal constitutional claims seeking to vindicate federal rights in domestic relations contexts, even when relief includes nullification of a domestic relations decree.
The appeals court found Johnson's Fourteenth Amendment due process claim was not obviously a 'mere pretense' to avoid the domestic-relations exception, noting her allegations that the state court removed her child without notice, adequate procedural protections, or findings of parental unfitness. The court concluded dismissal at the screening stage based on the domestic-relations exception was premature.