Bryan Brown v. Elizabeth Bowman
2012 U.S. App. LEXIS 1970
7th Cir.2012Background
- Brown applied for Indiana Bar admission; BLE required hearings and mental-health evaluations; JLAP referred Brown to psychiatrists; BLE denied Brown’s admission after evaluation process; Brown challenged via §1983 alleging religious bias and due process/First Amendment rights; district court dismissed under Rooker-Feldman and immunity defenses, which Brown appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman bars the federal claims. | Brown argues the suit attacks process, not the state judgment. | Defendants contend the claims are inextricably intertwined with the state court decision. | Rooker-Feldman bars the claims. |
| Whether Bowman, Ross, and Sudrovech are absolutely immune from suit. | Brown asserts immunity defenses fail to shield these actors. | Defendants rely on witness/official-immunity for court-appointed evaluators. | Immunity issue not necessary to decide; likely entitled to immunity. |
Key Cases Cited
- Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (establishes jurisdictional bar when state-court review is involved)
- Brokaw v. Weaver, 305 F.3d 660 (7th Cir. 2002) (Rooker-Feldman prerequisites and interrelation with state judgments)
- Edwards v. Ill. Bd. of Admissions to Bar, 261 F.3d 723 (7th Cir. 2001) (claims about bar admission process barred when intertwined with state decision)
- Hale v. Comm. on Character & Fitness for State of Ill., 335 F.3d 678 (7th Cir. 2003) (bar applicant raising similar federal claims before state court barred by Rooker-Feldman)
- Long v. Shorebank Dev. Corp., 182 F.3d 548 (7th Cir. 1999) (independent injury concept in intertwining analysis)
- Edwards v. Ill. Bd. of Admissions to Bar, 261 F.3d 723 (7th Cir. 2001) (reiterates mechanism of state-review bar for constitutional claims)