RODEL SARANGLAO MANIMTIM
v.
MARK RUBIN
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The court held that Younger abstention is appropriate for equitable relief claims and that claims against the defendant are barred by judicial and sovereign immunity.
[1] Younger abstention is appropriate when a state court has active oversight over the subject matter of a suit and substantial state interests exist, even if a formal state…
[2] Judicial absolute immunity applies to all actions of a judicial officer within their judicial jurisdiction, regardless of whether the claims are brought in an individual…
Previewing 2 of 6 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“judicial immunity is extended to officials other than judges [if] their judgments are functionally comparable to those of judges”
Establishes that judicial immunity can apply to non-judge officials whose duties are functionally similar to judicial responsibilities.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligencePlaintiff sued a state child support officer. The Magistrate Judge recommended dismissal, and the plaintiff objected. The complaint alleged contempt a…
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The Magistrate Judge issued a Report and Recommendation, recommending the dismissal of this suit at the screening phase. ECF No. 6. The Court furnished the Plaintiff a copy of the Report and Recommendation and afforded an opportunity to file objections pursuant to Title 28, United States Code, Section 636(b)(1). The Court has made a de novo determination of all timely filed objections. See ECF No. 7.
Having considered the Report and Recommendation and the timely filed objections, the Court agrees that Younger abstention is appropriate as to claims for equitable relief. Despite Plaintiff's argument that no state court “case” is currently pending, the complaint alleges that he has been found in contempt and is under threat of incarceration if he does not pay the arrearages. In these circumstances, the state
child support courts have active oversight over the arears underlying this suit and substantial state interests exist sufficient to invoke Younger, as in Pompey v. Broward Cnty., 95 F. 3d 1543, 1548 (11th Cir. 1996) (concluding there was a state court proceeding because the plaintiffs could be brought "before the court for civil contempt for any child support arrearage").
Additionally, the Court rejects Plaintiff's argument that the Magistrate Judge failed to consider his individual capacity claims. As discussed in the Report and Recommendation, the claims for damages are based on Defendant's conduct as a state court child support officer, duties that are functionally comparable to the responsibilities of a judge. See Antoine v. Byers & Anderson, Inc., 508 U.S. 429, 436 (1993) (stating "judicial immunity is extended to officials other than judges [if] their judgments are functionally comparable to those of judges") (internal alterations accepted and internal quotations omitted). And judicial absolute immunity applies to all actions of a judicial officer within their judicial jurisdiction, whether based on individual or official capacity. See Stevens v. Osuna, 877 F. 3d 1293, 1308 (11th Cir. 2017) (applying absolute immunity as protecting an immigration judge from damages for claims alleging both official and individual capacity conduct). The allegations show that Defendant was acting within his judicial capacity and not in the absence of all jurisdiction. Also, the Court agrees with the Magistrate Judge that
there was an opportunity for substantive review, and the official capacity claims are claims against the state, which has sovereign immunity. Therefore, the Report and Recommendation will be adopted.
Accordingly, it is ORDERED:
1. The Magistrate Judge's Report and Recommendation, ECF No. 6, is adopted incorporated by reference in this Order.
2. Plaintiff's complaint, ECF No. 1, is DISMISSED under the Younger abstention doctrine and because it seeks relief from an immune party.
3. All pending motions are DENIED as moot.
4. The Clerk of Court is directed to close the case.
DONE AND ORDERED this 20th day of January 2026.
M. Casey Rodgers M. CASEY RODGERS UNITED STATES DISTRICT JUDGE
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Pompey v. Broward Cnty. & Jack Osterholt, 95 F.3d 1543 (11th Cir. 1996)
- Antoine v. Byers & Anderson, Inc., 508 U.S. 429 (U.S. 1993)
- Stevens v. U.S. Attorney General, 877 F.3d 1293 (11th Cir. 2017)