Brahler-Barnes v. Arkansas Department of Human Services

IN THE UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF ARKANSAS
FORT SMITH DIVISION
KIMBERLY ANN BRAHLER-BARNES 	PLAINTIFF
V. 	CASE NO. 2:25-MC-00058
ARKANSAS DEPARTMENT OF
HUMAN SERVICES 	DEFENDANT
ORDER
Before the Court is the Report and Recommendation (“R&R”) (Doc. 5) of the
Honorable Mark E. Ford, United States Magistrate Judge for the Western District of
Arkansas. He screened the proposed complaint and determined that the Court lacks
jurisdiction because the case concerns a child custody dispute. Plaintiff Kimberly Ann
Brahler-Barnes, the mother of the child in question, filed an Objection to the R&R (Doc.
6) and Supplement (Doc. 7), which fail to address the Court’s lack of jurisdiction.
Upon de novo review, the Court agrees with the R&R. Federal courts do not have
jurisdiction over child custody disputes and may abstain from exercising jurisdiction over
a cause of action related to child custody. IT IS THEREFORE ORDERED that the
Objection is OVERRULED, the R&R is ADOPTED IN ITS ENTIRETY, and Plaintiff’s
“Emergency Motion for Temporary Restraining Order” (Doc. 1) and Supplemental
Complaint (Doc. 4) are DISMISSED WITHOUT PREJUDICE.
IT IS SO ORDERED on this 23rd day of March, 2026.
/s/ Timothy L. Brooks
TIMOTHY L. BROOKS
CHIEF UNITED STATES DISTRICT JUDGE
Case 2:25-mc-00058-TLB Document 8 Filed 03/23/26 Page 1 of 1 PageID #:
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