D'Angelo v. New Hampshire Supreme Court
740 F.3d 802
1st Cir.2014Background
- D'Angelo, a pro se attorney, had long-running family-court litigation in Derry Family Court concerning child support and alimony; the family court found him evasive about finances and held him in contempt multiple times.
- The Derry Family Court appointed attorney Brian Germaine as a Commissioner to investigate D'Angelo's income; Germaine reported higher income figures, the court adopted the report, entered judgment for the ex-wife (over $110,000), and modified prospective child support.
- D'Angelo sought discretionary review from the New Hampshire Supreme Court (NHSC); the NHSC declined review under NH Sup. Ct. R. 3, which treats domestic-relations appeals as discretionary.
- D'Angelo sued in federal district court seeking to enjoin enforcement of the state orders, to overturn the NHSC discretionary-denial rule as violating Due Process and Equal Protection, and to recover against Germaine for alleged investigative failures and misrepresentations.
- The district court dismissed the complaint: (1) Rooker–Feldman barred review of the state-court judgments; (2) No constitutional right to appellate review (Due Process) and Rule 3 survives rational-basis Equal Protection review; and (3) Germaine was protected by quasi-judicial immunity.
- The First Circuit affirmed: it rejected D'Angelo’s constitutional challenges to Rule 3 and held Germaine entitled to quasi-judicial immunity; the panel ordered D'Angelo to show cause why double costs should not be imposed for wasting judicial resources.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether NH Sup. Ct. R. 3 (domestic-relations appeals discretionary) violates Due Process by denying appellate review | D'Angelo: Rule 3 arbitrarily impedes access to courts by denying a right to appellate review for domestic-relations matters | NHSC: No constitutional right to appellate review; states may limit appellate docketing discretion | Held: No Due Process violation; Constitution does not guarantee appellate review (Lindsey controlling) |
| Whether Rule 3 violates Equal Protection by classifying domestic-relations appeals as discretionary | D'Angelo: Rule 3 creates an irrational class that deprives family-court litigants equal access | NHSC: Rule 3 distinguishes types of cases, not suspect classes; rationally related to legitimate interest in docket management | Held: Facial Equal Protection challenge fails under rational-basis review; Rule 3 is rationally related to legitimate state interest |
| Whether federal court may enjoin enforcement of state family-court orders | D'Angelo: Sought injunction of state orders and reversal of NHSC denial | NHSC/Defendants: Rooker–Feldman bars federal review of state-court judgments | Held: District court lacked jurisdiction under Rooker–Feldman; dismissal proper (not disturbed on appeal) |
| Whether Commissioner Germaine is liable for alleged investigative failures/misrepresentations | D'Angelo: Germaine failed to follow court orders, misrepresented facts, and had conflicts; thus not immune | Germaine: Appointed quasi-judicial officer performing judicial functions; entitled to absolute quasi-judicial immunity | Held: Germaine protected by quasi-judicial immunity; allegations of bad faith or imperfect performance do not overcome immunity |
Key Cases Cited
- Lindsey v. Normet, 405 U.S. 56 (1972) (no constitutional right to appellate review)
- San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973) (equal protection does not require precisely equal advantages; rational-basis review)
- Rogan v. City of Boston, 267 F.3d 24 (1st Cir. 2001) (recognizing right of access to courts principles)
- LCM Enters., Inc. v. Town of Dartmouth, 14 F.3d 675 (1st Cir. 1994) (rational-basis standard described for Equal Protection review)
- Hawes v. Club Ecuestre El Comandante, 535 F.2d 140 (1st Cir. 1976) (upheld a local rule against a facial equal-protection/access challenge)
- Aggarwal v. Ponce Sch. of Med., 745 F.2d 723 (1st Cir. 1984) (as-applied challenges to procedural access requirements may succeed where bond is onerous; court did not address facial constitutional invalidity)
- Nystedt v. Nigro, 700 F.3d 25 (1st Cir. 2012) (quasi-judicial immunity protects court-appointed officers performing judicial functions)
- Cok v. Consentino, 876 F.2d 1 (1st Cir. 1989) (bad faith or malice allegations do not automatically defeat judicial/quasi-judicial immunity)
- Miller v. Nichols, 586 F.3d 53 (1st Cir. 2009) (application of Rooker–Feldman doctrine barring federal challenges to state-court judgments)
- In re Simply Media, 566 F.3d 234 (1st Cir. 2009) (authority to award appellate costs for frivolous appeals)