Aaron Jacob Mindiola v. Arizona, et al.

In an Arizona divorce, despite A.R.S. §25_403(5)’s best-interests standard addressing the mental health of all parties, the court compelled only the dis­ abled-veteran father to disclose VA mental-health records and denied his request for reciprocal disclo­ sure of the mother’s mental health records under that standard. Then, in the absence of his mental health records, the state court imposed non-support penalties that the state enforcement agency later misclassified as child-support arrears and reported at the default 10% statutory rate contrary to the de­ cree. Oregon 9th Circuit affirmed dismissal and de­ nied leave to amend as futile. The questions pre­ sented are:

1. Whether a federal court may dismiss a pro se complaint and deny leave to amend as “futile” without (a) liberally construing the allegations under Johnson v. City of Shelby, 574 U.S. 10 (2014), to recognize a Title II ADA claim fairly disclosed by the facts, and (b) performing the claim-byclaim Eleventh Amendment analysis that United States v. Georgia, 546 U.S. 151 (2006), and Tennessee v. Lane, 541 U.S. 509 (2004), require for Title II claims.

2. Whether Ex parte Young, 209 U.S. 123 (1908), permits prospective relief against a state Title IV-D official to halt ongoing post-judgment en­ forcement that contradicts a decree and violates federal law—and, as necessary, whether a fur­ nisher’s legal misclassification (e.g., reporting court-ordered fees as “child-support arrears”) can be an actionable “inaccuracy” under the Federal Credit Reporting Act (FCRA).