MESADIEU
v.
WATERS
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Pro se plaintiff Mesadieu sought federal district court review of state circuit court family law decisions made by Judge Waters. The court denied plaintiff's amended motion for temporary restraining order, holding that federal district courts lack jurisdiction to review final state court judgments and that state judges enjoy judicial immunity for acts within their judicial role.
Federal district courts cannot review final state court judgments because that authority is reserved for state appellate courts. Additionally, state judges enjoy absolute judicial immunity from suit for judicial acts performed within their jurisdiction, and nothing in the allegations suggested Judge Waters acted outside his judicial role.
[1] Federal district courts cannot review state court final judgments; that task is reserved for state appellate courts.
[2] State courts have exclusive jurisdiction over family law matters.
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Join FLexlaw to unlock all legal intelligence“federal district courts cannot review state court final judgments because that task is reserved for state appellate courts”
Establishes the primary jurisdictional basis for denying plaintiff's motion
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Join FLexlaw to unlock all legal intelligencePlaintiff Mesadieu filed a complaint in federal district court challenging decisions made by Florida Circuit Judge Waters in a Polk County family cour…
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Plaintiff Kinisky Mesadieu, appearing pro se, filed a Complaint seeking to challenge decisions made by Florida Circuit Judge Waters in Plaintiff's Polk County Family Court case. (See generally Doc. 1). Plaintiff filed a separate Emergency Motion for Temporary Restraining Order (“TRO”) the same day, which was denied without prejudice for failure to comply with procedural rules. (See Docs. 3, 11). Plaintiff has since filed an Amended Motion for Temporary Restraining Order ("Amended TRO”) that cured many of the initial TRO's procedural defects. (Doc. 12). Nevertheless, the Amended TRO must still be denied.
As mentioned in this Court's previous Order (Doc. 11), federal district courts cannot review state court final judgments. See Casale v. Tillman, 558 F. 3d 1258, 1260 (11th Cir. 2009) (holding that federal district courts cannot review state court
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final judgments because that task is reserved for state appellate courts). And Florida law gives Florida state courts exclusive jurisdiction over family law matters. See Fla. Stat. §§ 26.012(2)(a), 34.01. Finally, as a general matter, state judges have judicial immunity from suit. Nothing in the allegations suggests that Judge Waters has operated outside of his role as a state circuit judge. See McCullough v. Finley, 907 F. 3d 1324, 1330 (11th Cir. 2018) (citing Stump v. Sparkman, 435 U.S. 349, 356– 57 (1978) (A judge enjoys “absolute immunity from suit for judicial acts performed within the jurisdiction of his court.")).
Accordingly, Plaintiffs Amended TRO (Doc. 12) is DENIED with prejudice. The Court advises Plaintiff that his claims may be more appropriately addressed by filing an appropriate motion in his Polk County Family Court case and/or in the Florida appellate court charged with reviewing such claims for Polk County state trial court judges, Florida's Sixth District Court of Appeal.
ORDERED in Tampa, Florida on June 27, 2025.
JOHN L. BADALAMENTI
UNITED STATES DISTRICT JUDGE
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Citator
Authorities Cited
- Stump v. Sparkman et vir, 435 U.S. 349 (U.S. 1978)
- Casale v. Tillman, 558 F.3d 1258 (11th Cir. 2009)
- McCullough v. Finley, 907 F.3d 1324 (11th Cir. 2018)