Unreported / Non-Citable
Background
In November 2025, the Northern District dismissed without leave to amend Chikodi Chima’s federal lawsuit against 88 defendants alleging a sprawling conspiracy arising from his state-court child custody litigation. Chima v. Perkins, 2025 WL 3182071 (N.D. Cal. Nov. 5, 2025). Soon after, Chima refiled — this time against 26 defendants (many of them named in the prior case), including lawyers, law firms, individuals who provided witness statements supporting his former spouse, social workers, police officers, financial and insurance companies, the City and County of San Francisco, and others. Magistrate Judge Thomas Hixson screened the Second Amended Complaint under 28 U.S.C. § 1915(e) and recommended dismissal again on domestic-relations abstention grounds. Chima objected.
The Court’s Holding
Judge Charles Breyer adopted Judge Hixson’s Report and Recommendation in full and dismissed the case without leave to amend (but without prejudice to Chima bringing suit in an appropriate forum).
Under the domestic-relations abstention doctrine — articulated in the Ninth Circuit by Coats v. Woods and Csibi v. Fustos and applied repeatedly by Northern District judges — federal courts decline to hear cases that, while ostensibly raising constitutional or statutory claims under § 1983 or § 1981, are at their core child custody disputes. Even allegations of a “massive conspiracy by judges, legislators, attorneys, and a court psychologist” do not change the analysis if the underlying matter is a custody dispute. Csibi specifically warned that allowing plaintiffs to escape the abstention doctrine “by pleading an independent tort” would let any creative pleader pull child and spousal support matters into federal court.
Chima conceded that his conspiracy claims arose from a “family law matter and custody determinations.” His allegations centered on a scheme to commit fraud through false evidence and testimony in his state-court proceedings. Adding additional individual and institutional defendants did not transform the case out of the domestic-relations exception.
Chima also argued that he was barred from pursuing his complaints in state court, citing a letter from the San Francisco County Superior Court’s Chief Executive Officer. The court found the letter only said the administrative office of the court did not handle complaints about individual sheriffs and directed Chima to the Sheriff’s Office. It did not say Chima was barred from filing or accessing the courthouse, and it said nothing about the many other defendants in the federal case. There remained a state-court forum, so abstention was appropriate. The court also rejected the request for further leave to amend.
Key Takeaways
- The Ninth Circuit’s domestic-relations abstention doctrine is broad. Under Coats v. Woods and Csibi v. Fustos, federal courts will decline to hear cases that are at their core custody or family-law disputes, even when § 1983, § 1981, or constitutional claims are formally pleaded.
- Adding additional defendants — financial institutions, employers, social workers, police officers — does not extricate a custody case from the abstention exception. The pleading’s core, not its caption, controls.
- To overcome the doctrine on the basis that there is no available state forum, a plaintiff must show actual exclusion from the state courts. Letters about administrative-complaint procedures are not enough.
- Once a federal court has dismissed a domestic-relations-style case without leave to amend, refiling under a slightly different defendant list will likely face the same outcome on screening under 28 U.S.C. § 1915(e).
Why It Matters
Federal courts in California regularly receive sprawling pro se complaints arising from state-court family-law disputes — alleging fraud, conspiracy, and constitutional violations against judges, lawyers, social workers, and the agencies that touched the litigation. The domestic-relations abstention doctrine is the principal screening mechanism that keeps these cases out of federal court, and the Northern District applies it consistently.
The opinion is also a small but instructive illustration of the procedural reality of repeat filings. After dismissal without leave to amend, plaintiffs sometimes refile with a slightly different defendant list and theory; the result is generally the same. The court’s explicit statement that the dismissal is without prejudice to filing in an appropriate forum (i.e., state court) underscores the path forward for litigants whose grievances actually do belong somewhere — just not federal court.