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Miller v. Nichols

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Before Lynch, Chief Judge, Torruella and Boudin, Circuit Judges.

Plaintiffs are the parents of a child removed from them by the state after extensive proceedings resulted in a finding that the best interests of the child required termination of their parental rights. In re G.M., No. PC-05-75 (Me. D. Ct. Jan. 23, 2008). The parents then sued in federal court, asserting violations of statutory and constitutional rights during the termination proceedings and particularly in reunification efforts mandated by state law. They sought injunctive relief to prevent a foster family’s adoption of the child, as well as monetary damages.

Plaintiffs appeal from a district court order dismissing their suit for lack of jurisdiction and on the basis of issue preclusion. Because the injunction sought would negate the state court’s judgment and because the factual issues underpinning plaintiffs’ present claims for damages were addressed by the state court, the district court’s dismissal on Rooker-Feldman and on issue preclusion grounds was appropriate. We affirm.

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