Thanks for visiting! Welcome to a new way to research case law. You are viewing a free summary from Descrybe.ai. For citation and good law / bad law checking, legal issue analysis, and other advanced tools, explore our Legal Research Toolkit — not free, but close.
Sarah Whittier Brown v. District of Columbia Bartolome Bestard Bonet Holmes Cheney Brown Morton Berg, Hearing Commissioner Honorable James W. Washington, Jr. Roger A. Finzel Leonard L. Koenick David A. Gespass A. Hugh Douglas, U.S. Consul 1973 Richard G. Haegele, U.S. Consul 1973/74 American Friends Service Committee, Inc. And Margaret Anne Shaker
Citations: 113 F.3d 1245; 1997 U.S. App. LEXIS 18526; 1997 WL 235605Docket: 96-2238
Court: Court of Appeals for the Tenth Circuit; May 8, 1997; Federal Appellate Court
Sarah W. Brown, representing herself, appealed the dismissal of her complaint, which sought to declare a 1973 divorce decree issued by the District of Columbia Superior Court void under the Declaratory Judgment Act (28 U.S.C. § 2201). The district court dismissed the case for lack of subject matter jurisdiction, stating that the matter fell within the domestic relations exception, which prevents federal courts from adjudicating issues related to divorce, alimony, or child custody. The court noted that Brown was not involved in the divorce proceedings due to undergoing psychiatric treatment in Malta at that time. The appellate court reviewed the case and agreed with the district court's conclusion regarding the lack of jurisdiction. Citing established case law, including *Ankenbrandt v. Richards* and *District of Columbia Court of Appeals v. Feldman*, the court affirmed that federal courts cannot review state court judgments, even on constitutional grounds. Additionally, Brown's motion to proceed in forma pauperis was denied, and her appeal was dismissed. Her request to supplement the record was also denied. The judgment serves as a reminder that orders and judgments are generally not binding precedents, apart from specific legal doctrines. The panel noted similar previous dismissals of other actions filed by Brown in the District of Columbia Circuit.