Chaganti v. Matal
695 F. App'x 545
| Fed. Cir. | 2017Background
- Naren Chaganti, a Missouri-licensed attorney and registered PTO practitioner, was investigated after a complaint alleging he communicated with a represented party and made threatening conduct, violating Mo. Sup. Ct. R. Prof. Conduct 4-4.2 and 4-8.4(d).
- A Disciplinary Committee held an evidentiary hearing in January 2014; Chaganti testified, participated in discovery, and cross-examined adverse witnesses. The Panel found violations and imposed indefinite suspension, with reinstatement eligibility after six months.
- The Missouri Supreme Court affirmed the misconduct findings and maintained suspension but extended the earliest reinstatement to one year.
- The PTO, under its reciprocal-discipline rule (37 C.F.R. § 11.24), instituted reciprocal discipline based on the Missouri decision; the PTO Director imposed the identical sanction after finding Selling-factor challenges unproven.
- Chaganti sought district-court review under 35 U.S.C. § 32; the Eastern District of Virginia affirmed the PTO Director’s order under the APA standard. Chaganti appealed to the Federal Circuit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether PTO procedures denied due process | Chaganti: PTO allows reciprocal discipline where original forum used a lower proof standard, places burden on practitioner, and denied an oral hearing | PTO: Chaganti waived these arguments by not raising them before the PTO | Waived; not considered on appeal |
| Whether Missouri procedure lacked notice/opportunity to be heard (Selling factor i) | Chaganti: Procedure deprived him of due process | PTO: Chaganti participated in discovery, hearing, testimony, and cross-examination; procedural rulings were within discretion | Held: No due-process deprivation; Selling factor i fails |
| Whether proof was infirm (Selling factor ii) | Chaganti: Record proof was insufficient to support discipline | PTO: Record contained adequate evidence of the misconduct | Held: Proof sufficient; Selling factor ii fails |
| Whether imposing identical suspension would cause grave injustice (Selling factor iii) | Chaganti: Reciprocal discipline would be unjust given circumstances | PTO: Missouri sanction was within applicable ABA standards for unauthorized contact and threatening conduct; suspension appropriate | Held: No grave injustice; reciprocal suspension upheld |
Key Cases Cited
- Selling v. Radford, 243 U.S. 46 (U.S. 1917) (standards for refusing to give effect to foreign disciplinary findings)
- Bender v. Dudas, 490 F.3d 1361 (Fed. Cir. 2007) (APA standard governs review of PTO disciplinary orders)
- Sheinbein v. Dudas, 465 F.3d 493 (Fed. Cir. 2006) (standard of review for district-court review of PTO disciplinary orders)
- In re Squire, 617 F.3d 461 (6th Cir. 2010) (due-process requirements satisfied where practitioner participated in hearings, presented evidence, and cross-examined witnesses)
- In re Attorney Disciplinary Matter, 98 F.3d 1082 (8th Cir. 1996) (no grave injustice where original discipline fell within appropriate range of sanctions)