Unreported / Non-Citable
Background
Mary Ruffin sued Remy Real Estate Investment Inc. for negligence in Texas justice court in 2020. After the justice court dismissed for lack of standing, Ruffin appealed to county court, where she received a take-nothing judgment following a bench trial. A Texas court of appeals affirmed that judgment in 2025.
Ruffin then brought this federal action under 42 U.S.C. § 1983 against Remy, its attorney Keith Gross, and court reporters Lani Harkey and Dale Lee. She alleged due-process, equal-protection, conspiracy, and denial-of-access-to-courts claims based on matters including the state courts’ handling of her indigency status, transcripts, discovery, trial procedure, and evidence. She also alleged that Gross improperly placed her driver’s-license information in the public court record.
The Court’s Holding
Magistrate Judge Andrew M. Edison recommended granting the motions to dismiss. Under the Rooker–Feldman doctrine, the court lacked subject-matter jurisdiction over the claims against Harkey and Lee because granting relief—including ordering free transcripts—would effectively reverse the state court’s indigency ruling. The doctrine likewise barred claims against Gross and Remy insofar as they asked the federal court to reject state-court decisions concerning indigency, standing, trial management, and evidence.
The claims concerning Gross’s alleged disclosure of personal information were not barred by Rooker–Feldman, but they failed under § 1983 because Gross and Remy were private parties and Ruffin did not plausibly allege that a state judge knowingly participated in a conspiracy with them. The magistrate judge also recommended denying Ruffin’s preliminary-injunction motion and denied her remaining motions, including leave to supplement because the proposed claims would be futile.
Both sanctions motions were denied. Ruffin’s motion was denied because Gross’s pleadings were not frivolous and correctly argued that her claims should be dismissed. Gross’s Rule 11 motion was denied because he could not have complied with the mandatory 21-day safe-harbor requirement; the court separately declined to impose inherent-power sanctions because Ruffin had not acted in bad faith.
Key Takeaways
- Rooker–Feldman bars federal claims whose requested relief would effectively reverse or void a prior state-court ruling, but it does not automatically bar claims based on independent pre-judgment conduct.
- A private attorney and client do not become state actors merely by using the courts, prevailing in litigation, complying with a judgment, or allegedly providing misinformation that influences a ruling.
- Rule 11’s 21-day safe-harbor requirement is mandatory, and failure to serve the proposed sanctions motion before filing forecloses relief.
Why It Matters
The recommendation illustrates the boundary between an impermissible federal challenge to a state-court judgment and an independent claim arising from litigation conduct. Even where Rooker–Feldman does not remove jurisdiction, a § 1983 plaintiff must still plausibly allege state action rather than rely on conclusory assertions of collusion.
It also underscores that sanctions requests require distinct substantive and procedural analyses: Ruffin’s motion failed on the merits, while Gross’s Rule 11 motion failed for noncompliance with the safe-harbor procedure.