Kraemer v. Spitale
CourtDistrict Court, District of Columbia
Date FiledAugust 18, 2026
DocketCivil Action No. 2026-1962
JudgeJudge Amit P. Mehta
StatusPublished
📰 News Coverage: Read the LAWS.com news report on this case
Full Opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
THOMAS KRAEMER, )
)
Plaintiff, )
)
v. ) Civil Action No. 26-1962 (UNA)
)
LISA SPITALE, ESQ., )
)
Defendant. )
MEMORANDUM OPINION
This matter is before the Court on review of Thomas Kraemer’s application to proceed in
forma pauperis (ECF No. 2) and pro se complaint (ECF No. 1). The Court GRANTS the
application, and for the reasons discussed below, DISMISSES the complaint and this civil action
without prejudice.
Plaintiff, a New York resident and principal of Kraemer, Inc., is the natural father of
Emilie Kraemer. See Compl. ¶¶ 23, 25. He brings this action against Lisa Spitale, Esq., who
continues to serve as Emilie’s guardian, see id. ¶¶ 26, 29, having been appointed by the Court of
Common Pleas of Northampton County, Pennsylvania, Orphans Court Division, see e.g., id. ¶
26. According to Plaintiff, Defendant’s appointment is void ab initio, see id. ¶ 27, and Plaintiff
appears to challenge every decision made by Defendant and others with respect to Emilie’s
education, care, and treatment, as well as the expenditure of funds on Emilie’s behalf, see, e.g.,
id. ¶¶ 28-29. In addition to monetary damages, Plaintiff demands an Order “vacating the
fraudulent guardianship appointment as void ab initio and restoring Plaintiff’s parental rights and
access to his daughter.” Id. at 61. This the Court cannot do. Generally, a federal district court
lacks jurisdiction to review or overturn the rulings of a state court. See, e.g., Hankins v. North
1
Carolina, No. 21-5156, 2021 WL 4765428, at *1 (D.C. Cir. Oct. 7, 2021) (per curiam) (finding
that “district court correctly concluded that it lacked jurisdiction over appellant’s claims, which
sought review of adverse decisions of the North Carolina state courts”). Further, “[f]amily
relations are a traditional area of state concern,” Moore v. Sims, 442 U.S. 415, 435 (1979), and
the federal courts “customarily decline[] to intervene [in] the realm of domestic relations,” Elk
Grove Unified School Dist. v. Newdow, 542 U.S. 1, 12 (2004).
An Order is issued separately.
DATE: August 18, 2026 AMIT P. MEHTA
United States District Judge
2