A federal civil rights suit over termination of a father’s parental rights was wrongly dismissed based on the outcome of a related state court case, the U.S. Court of Appeals for the Third Circuit has ruled.
The father’s suit in U.S. District Court in Newark, Mazzetti v. Wood, 13-2095, was dismissed based on the Rooker-Feldman doctrine, which says a district court may not exercise jurisdiction over a case by a party who loses a state court proceeding and invites federal court review of that judgment. The district court analysis focused on whether the federal court suit was “inextricably intertwined” with proceedings in Bergen County Superior Court, where Dennis Mazzetti’s parental rights were terminated.
