Campbell v. City of Spencer, No. 11-6041 (10th Cir. 2012)
Annotate this CasePlaintiff-Appellant Dr. Ann Elaine Campbell put horses out to pasture on land she owns in two Oklahoma municipalities, Defendants-Appellees the City of Spencer (the City) and the Town of Forest Park (the Town). After an animal-welfare investigation, City and Town authorities executed search warrants and seized 44 horses from her properties. The two municipalities successfully petitioned a state court to order forfeiture of the horses unless the owner posted a security bond to pay for their maintenance from the date of seizure. After unsuccessfully appealing the forfeiture and bond determinations in state court, Plaintiff filed an action under 42 U.S.C. 1983 in federal court against the City and the Town, alleging that they violated the Fourth Amendment by unlawfully searching her property and seizing her horses; the Fifth Amendment by depriving her of her horses without due process or just compensation; and the Eighth Amendment by obtaining an excessive fine through an unreasonable forfeiture bond. The court held that it lacked jurisdiction under the "Rooker-Feldman" doctrine. On appeal Plaintiff contended that the district court erred in applying the Rooker-Feldman doctrine. Upon review, the Tenth Circuit affirmed in part, reversed in part, and remanded for further proceedings: "[The Court] agree[d] that the district court lacked jurisdiction to consider the Fifth and Eighth Amendment claims, which [were] barred by Rooker-Feldman because they challenged the state court judgment; but it erred in dismissing the Fourth Amendment claims to the extent that they concern[ed] preforfeiture events."
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