Cooper v. Ramos, et al, No. 11-57144 (9th Cir. 2012)
Annotate this CasePlaintiff was convicted of four counts of first-degree murder and sentenced to death in 1995. Plaintiff filed suit in federal district court in California challenging a state court's denial of his request to obtain additional DNA testing pursuant to a state statute. Plaintiff alleged that he was the target of a conspiracy involving members of the county sheriff's department and others. The district court dismissed on the basis that it lacked subject matter jurisdiction under the Rooker-Feldman doctrine. Under that doctrine, the federal courts lacked subject matter jurisdiction over his first claim, which sought federal relief from the state court's determination in the DNA proceeding, and over his second and third claims, which were inextricably intertwined with the first. Therefore, the court agreed with the district court that his complaint was properly dismissed. The court also held that the district court did not err in implicitly denying plaintiff's request to amend his complaint.
Court Description: Civil Rights. The panel affirmed the district court’s dismissal of a complaint brought by Kevin Cooper, who was convicted of murder and sentenced to death in 1985, challenging a state court’s denial of his request to obtain additional DNA testing pursuant to a state statute. Cooper alleged that he was the target of a long-running conspiracy, involving members of the San Bernardino County Sheriff’s Department and others, to manipulate evidence and prevent him from proving that he was framed. The district court dismissed the complaint without prejudice, to the extent that Cooper was able to plead viable claims that were not barred by the Rooker-Feldman doctrine. The panel first determined that the district court intended its order to be final and appealable and therefore the panel had jurisdiction to consider the ruling. The panel then held that the district court properly dismissed the complaint under the Rooker-Feldman doctrine because the federal courts lacked subject matter jurisdiction over Cooper’s first claim, which sought federal relief from the state court’s determination in the DNA proceeding, and over his second and third claims, which were inextricably intertwined with the first. The panel further held that the district did not err in implicitly denying Cooper’s request to amend the complaint.
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