{"id":434,"date":"2026-01-08T12:00:00","date_gmt":"2026-01-08T12:00:00","guid":{"rendered":"https:\/\/california.shuster.info\/?p=434"},"modified":"2026-01-08T12:00:00","modified_gmt":"2026-01-08T12:00:00","slug":"blount-contra-costa-superior-court-domestic-relations-rooker-feldman","status":"publish","type":"post","link":"https:\/\/california.shuster.info\/?p=434","title":{"rendered":"Blount v. Superior Court of Contra Costa \u2014 N.D. Cal. abstains from custody and vexatious-litigant intervention"},"content":{"rendered":"
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Case<\/dt>\n
Alivia Blount v. Superior Court of California, County of Contra Costa, et al.<\/dd>\n
Court<\/dt>\n
U.S. District Court \u2014 Northern District of California<\/dd>\n
Date Decided<\/dt>\n
2026-01-08<\/dd>\n
Docket No.<\/dt>\n
3:25-cv-10852<\/dd>\n
Status<\/dt>\n
Unreported \/ Non-Citable<\/dd>\n
Topics<\/dt>\n
Domestic relations abstention; Ankenbrandt v. Richards<\/em>; Csibi v. Fustos<\/em>; Coats v. Woods<\/em>; Rooker-Feldman doctrine; Kougasian v. TMSL<\/em>; vexatious-litigant designation<\/dd>\n<\/dl>\n<\/div>\n

Background<\/h2>\n

Alivia Blount is engaged in a Contra Costa Superior Court family-law dispute over custody and visitation of her child. As the out-of-state parent, she has no legal or physical custody and no visitation rights, while her wages are garnished for child support. She filed numerous motions in state court to modify the arrangement. In April 2025, the state court designated her a vexatious litigant and imposed a pre-filing approval requirement. After she made many additional filings, the state court in July 2025 stayed all unauthorized litigation. She petitioned the California Court of Appeal for a writ of mandate, which was denied in June 2025, and the California Supreme Court denied review in November 2025. She has filed at least six appeals.<\/p>\n

Blount then sued Contra Costa County, the Contra Costa Superior Court, and Judge Gina Dashman in the Northern District of California, seeking declaratory and injunctive relief to: compel the state court to hear and prioritize her motions; suspend child support; order restitution of all child support paid since January 2023; consider purportedly new evidence; and declare the vexatious-litigant designation improper. She also moved for a preliminary injunction.<\/p>\n

The Court’s Holding<\/h2>\n

Judge Charles R. Breyer denied the motion and dismissed the case.<\/p>\n

On the abstention question, the court applied the domestic-relations abstention doctrine articulated in Ankenbrandt v. Richards<\/em>, Csibi v. Fustos<\/em>, and Coats v. Woods<\/em>. The doctrine divests federal courts of power to issue divorce, alimony, and child-custody decrees, and Ninth Circuit doctrine extends abstention even to constitutional claims that are at their core child-custody disputes. Blount\u2019s case was not tangentially related to custody; it asked the federal court to halt child support, compel restitution, and intervene in ongoing family-law proceedings. Abstention was therefore required. The state court remained an available forum, and the appellate courts had not foreclosed Blount\u2019s ability to seek relief there.<\/p>\n

On the request to invalidate the vexatious-litigant designation, the court invoked the Rooker-Feldman doctrine. Under Kougasian v. TMSL<\/em> and Skinner v. Switzer<\/em>, federal district courts cannot sit as appellate reviewers of state-court judgments. The court cited Brown v. Evans<\/em> for the rule that requests to enjoin enforcement of a state-court vexatious-litigant determination are barred by Rooker-Feldman. The case was dismissed without prejudice to Blount raising her concerns in state court.<\/p>\n

Key Takeaways<\/h2>\n