Cathy Mestman v. Linda Jones
670 F. App'x 752
| 3rd Cir. | 2016Background
- Cathy Mestman is a serial litigant in New Jersey landlord-tenant disputes; she previously filed a federal suit challenging a state eviction order (this Court affirmed dismissal).
- On Sept. 12, 2016, a New Jersey Superior Court judge (Hon. Linda Grasso Jones) entered an ejectment order removing Mestman from a condominium owned by Herbert Feldman.
- Mestman filed a federal complaint naming Feldman and Judge Jones, alleging Feldman (her former psychologist) perjured himself about renting the unit and alleging Judge Jones was biased and violated court procedures.
- She sought no specific federal relief but effectively sought invalidation of the state-court ejectment and complained of injuries (homelessness, loss of access to belongings) caused by the order.
- The District Court granted in forma pauperis status but dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B) for lack of jurisdiction and judicial immunity; Mestman appealed.
- The Court of Appeals affirmed, dismissed pending motions, barred Mestman from calling court offices due to abusive behavior, and warned of possible sanctions for further abuse.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court has jurisdiction to review state-court ejectment order (Rooker–Feldman) | Mestman sought relief from the ejectment and alleged injuries from the state judgment | District courts lack jurisdiction over claims seeking to overturn state-court judgments (Rooker–Feldman) | Dismissed: Rooker–Feldman bars federal review of the state-court ejectment order |
| Whether claims against the state judge are viable | Judge Jones’ conduct at the ejectment hearing violated rules and was biased | Judicial acts are protected by absolute judicial immunity | Dismissed: judicial immunity bars civil claims against Judge Jones for actions in judicial capacity |
| Whether Feldman can be sued in federal court for alleged perjury | Feldman perjured himself at the state proceeding, causing injury to Mestman | Perjury allegations do not present a federal claim sufficient to overcome jurisdictional defects | Dismissed: no conceivable federal claim against Feldman arising from alleged perjury |
| Whether appellate jurisdiction exists in this Court and post-dismissal restrictions | Mestman sought relief by appeal and continued contact with court staff | Appeal permitted only from final decisions; abusive contacts may be curtailed | Affirmed dismissal; prohibited Mestman from calling court offices and warned of sanctions |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (establishes Rooker–Feldman framework)
- Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir. 2010) (applies and explains Rooker–Feldman in this circuit)
- Rooker v. Fid. Trust Co., 263 U.S. 413 (1923) (origin of federal-court nonjurisdiction over state-court judgments)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (1983) (Rooker–Feldman progenitor)
- Mireles v. Waco, 502 U.S. 9 (1991) (absolute judicial immunity for judicial acts)
- Capogrosso v. Supreme Court of N.J., 588 F.3d 180 (3d Cir. 2009) (per curiam) (application of judicial immunity in this circuit)
- Allah v. Seiverling, 229 F.3d 220 (3d Cir. 2000) (standards for appellate jurisdiction and plenary review)