Backdated court judgments
Jean Dominique Morancy v. Sabrina Alex Salomon
In brief
- Where it stands
- Dismissed
Petition denied.
- What it’s about
- In a case against Sabrina Alex Salomon, Jean Dominique Morancy asked the Supreme Court to review whether a Florida trial court could enter a judgment dated retroactively to a time when it allegedly lacked jurisdiction, whether limits on state review violated due process, and whether federal courts could decline related claims.
- Who it affects
- Morancy received no Supreme Court review; the Court did not resolve his claims about the judgment or related state and federal court procedures.
Summary: written with AI from the case record.

What it's about
The Court refused to hear the case (denied review) and did not decide those questions.
The dispute began in Florida state court, but Morancy also questioned how federal courts handled related claims.
Question presented
1. In Roman Catholic Archdiocese of San Juan v. Acevedo Feliciano, 140 S. Ct. 696 (2020), this Court held that courts may not use nunc pro tunc orders to retroactively create jurisdiction (facts) where none existed. Does a state appellate court violate the Fourteenth Amendment ’ s Due Process Clause when it affirms — via an unreviewable Per Curiam Affirmance — a trial court judgment entered nunc pro tunc to a date when the trial court demonstrably lacked subject matter jurisdiction? 2. Does Article V, § 3(b)(3) of the Florida Constitution, which categorically prevents the Florida Supreme Court from reviewing unwritten Per Curiam Affirmances (PCAs), violate the Fourteenth Amendment Due Process Clause as applied, when it operates to permanently insulate structurally void orders from state supreme court supervision, thereby precluding an "adequate and independent state ground" for denial of relief under Michigan v. Long, 463 U.S. 1032 (1983)? 3. May federal courts lawfully invoke Younger abstention to permit the federal enforcement of void state arrears (e.g., U.S. Treasury offsets and passport revocation), or invoke the Rooker-Feldman doctrine to dismiss related federal civil claims, when the underlying state judgment is a nullity ab initio, or does such application unconstitutionally incentivize state tribunals to weaponize void orders without fear of federal review?
Documents
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
More questions
- Was oral argument held?
- No. Argument had not been scheduled before the Court denied review.
- Did the Court decide whether the trial court lacked jurisdiction?
- No. The Court did not decide that question.
- Does the denial mean the Court agreed with the Florida court?
- No. Refusing to hear the case does not signal approval of either side's position.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.