it lana and judge show flat is in jacksonville and we have three appeals that are scheduled for argument this morning and we're ready to proceed i would advise counsel that we have read the briefs that we have all relevant parts of the record that will assist you in there or in the focus of your arguments for the time that you have available that's got us as the court with debbie and she will serve d as the time keeper and she will let you know when your time has expired and before d that she will give you a two minute warning so it looks like we are ready to proceed with the st case st cases rebecca in the bay area lewis there versus james campbell here the district court looks at what it believes to be the core of the entire complaint rather than of individual claims and that's important here because i doing so the court has missed several constitutional claims that this court and others have h not present at the hearing employment represented by counsel and here we have a similar case for baucus now a young adult and she's raising these claims and there's also an allegation that she wasn't able that she wasn't afforded consider matters outside of the pleadings so that means they could have presented avenue you can have affidavits etc here my claims were not afforded that opportunity the only thing that we have before us on the record on appeal research in future claim here even if it's based on the fact that that there was no evidence considered in the state court i would argue that good men now could also stand for the proposition that after x non mobile even if that claim had been raised in state court that the supreme court has said that even if there is even if there was a claim that was litigated in the state for or if it if it's something that's been i don't recall conclusion as long as there is some independent claim that their skill is a little bit difficult for me to tell from the complaint what relief your clients are seeking for the claim they're focusing on here can you tell me for each of the claims that you're what do you think after i found the evil how would you describe the inexplicably intertwined cast and does that make a difference for how we respond to the claims of  good morning in a minute please the court my name is sean fay he i'm here today on behalf of two of the apple e's dr james campbell who's the principal of sentinel ridge high school and the school district of palm beach county  really the school board of beach county so listen rebecca bear's seventy five page nd amended complaint is what this court has called a shotgun complaint and so for an individual defendant faced with trying to respond to it we cannot say that there's there's a whole lot in the nd amended complaint that we would call clear factually or legally but it is pretty clear from reading it what motivates the federal claims that are brought by the bears in this case and that is that the bears believe that the state courts have weaponized against them and they claim that they have been injured by a series of result following three reasons st the district court properly dismissed this attack on state court proceedings and state court rulings excuse me under the record feldman doctrine and any argument that the dismissal should not have been with or that another opportunity to amend should have been aborted has been abandoned in this appeal and nd and rd two related reasons the district court's dismissal with prejudice was appropriate because this was another shot well start with the name of our the the state law tort claims argument is not the record filmon bars those those are state law claims and because there are not federal claims here that are not barred any state law can and should be dismissed for lack of jurisdiction so the court does need to analyze whether the state law claims survive rycroft for the due process in the discrimination claims under this court's reasoning in goodman those are those are pretty clear case for ricker feldman because what the bears are saying is  proceedings were initiated were based upon the ever cations lies fraud conspiracy whatever else it may be and that improper considerations factored into the state court's judgment they improperly considered mr barry's age the age difference between him and his his former spouse they failed to take into account the needs of the children with respect to disabilities their educational needs the religious practices of the family all of those criminalization and due process claims are squarely asking the district court to decide that state court wrongly decided the issues before it that its judgment should effectively be nullified because it was based on improper considerations or incompetent evidence not dispositive whether a case is styled as an appeal it's not dispositive what relief is sought what's dispositive under dublin is what the court is being asked to do and what the court is being asked to do is effectively it's going to be forced to decide state court decision was wrong because it well we have cited case law in our brief your honor to explain it due process challenges constitutional challenges and i believe i believe mr norbury knowledge of this can be raised on appeal in florida opportunity to raise the claims which is a reason not to apply the bar but want to enter something you said which is that as an alternative basis for dismissal here just for just for the two of kelly's letter before the court today dr this is virtually indiscernible from the from the pleading and just answer judge wilson's question on the search and seize your discordia goodman did say that such a claim was not barred because it did not there was no indication that it was really part of the proceedings it was an independent act that took place before any state court rulings but as we've explained in our brief that's not clear from this complaint in fact really the search and seizure claim in the nd many complain is pretty bare bones of just actually just  federal jurisdiction the bears have a burden and i recognize a pro se but they still have the burden of alleging facts that show the federal jurisdiction exists which would include facts that show this their claims are not precedents or exxon mobile you can just say well this all it's pretty generally like it may have been covered under state law sort of just the center of a phone line because they haven't shown us that we can't do you do you think the court  something different than that here i think the court your honor took took the bears at their word about what their complaint was about they describe their case as simple they say it's one of the many examples have any facts so analyzing just a handful of facts that are actually alleged in the nd complaint of the district court properly assess the complaint for what it is an attack on state court judgments that said you know we've rents aren't even disputing or part there are a handful where it's arguable at best but they don't but this is clearly a shocking complaint you know it falls into three of the four categories this court identified  it believes the search and seizure claim is not barred but given that this is a shotgun complaint given that the search and seizure claim is bereft of any factual support in the complaint there's just no reason to do that there's no reason to expend that  would say in response to the argument that the district court out that's right by really looking at the essence of the claims this actually is a very district court orders incredibly similar to the order that entered by the just reporting goodman the court has said on the plaintiffs are essentially challenging the basis of the juvenile court of cobb county and as you are aware the court went through and looked at the individual claims and decided that that some were barred and some were not with regard to the search and seizure claims to the extent that goodman requires that the state court didn't consider the  we there's no allegation here because the court only looked at as a complaint and there's no allegation or evidence showing that that evidence was relied on or that it was raised and in a court and to the extent that that was required from us as you know our burden of showing subject matter jurisdiction we were we were denied we were not afforded an opportunity to brief the huge present evidence on a subject matter for fiction and therefore on use allegation it survived and as i mentioned in my in my arguments that i still believe that this is an independent claim even if it independent and to the extent while we believe that the allegations themselves are sufficient to show that were filed and does not bar the claims that we identified to the sense of the court disagreed we should be given that