Dillon-Capps v. Ohana Growth Partners, LLC
1:24-cv-03744
D. MarylandJan 8, 2025Background
- Plaintiff, Ryan Dillon-Capps, filed a pro se federal lawsuit against his former employer (Ohana Growth Partners, LLC), several former coworkers, opposing counsel, state court judges, court staff, and Maryland ethics officials, following an adverse state court employment-related action.
- The state court had previously issued an injunction and imposed contempt fines against Dillon-Capps in a dispute with Ohana related to his employment contract; Dillon-Capps alleged the underlying state suit was retaliatory, based on his FMLA leave, and asserted a wide-ranging conspiracy.
- Dillon-Capps brought 22 counts with over 170 subcounts, alleging violations of the FMLA, ADA, various constitutional rights, fraud statutes, conspiracy, and violations of federal and state consumer protection laws.
- Defendants included Ohana and its employees, state court judges, the Clerk of Court, opposing counsel, and leaders of state legal ethics bodies; Dillon-Capps also attempted to bring claims against the State of Maryland.
- The state court matter was voluntarily dismissed before this federal action was filed; Plaintiff sought leave to proceed in forma pauperis and moved for numerous forms of extraordinary relief, including emergency hearings and institutional oversight.
- The federal court granted in forma pauperis status but screened the complaint under §1915(e)(2)(B), and, citing numerous legal doctrines and pleading deficiencies, dismissed many claims outright, directed amendment, and warned Plaintiff against noncompliance.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Federal court jurisdiction over state court rulings (Rooker-Feldman) | State proceeding and resulting injunction were unlawfully retaliatory and violated federal rights | Plaintiff is seeking appellate review of a state court decision, which is barred | Court lacks subject matter jurisdiction; claims dismissed under Rooker-Feldman |
| Judicial/Quasi-Judicial Immunity | Judges acted outside jurisdiction due to alleged Norris-LaGuardia Act violations | Acts were within judicial function, and judges/staff are immune | Claims against judges/clerks dismissed under absolute immunity |
| Claims against Maryland state agencies/officials (Sovereign Immunity) | State facilitated harm and should be liable for damages; ongoing violations alleged | State has Eleventh Amendment immunity; no plausible claim of ongoing violation or proper defendant | State dismissed from suit; damages barred; no valid prospective injunctive claim |
| Conspiracy and Ethics Commission failures | Defendants conspired in adverse rulings; ethics officials failed to act on grievances | No plausible or legally sufficient conspiracy or right to investigation claim | Conspiracy claims and grievances against ethics officials dismissed |
Key Cases Cited
- D.C. Ct. of Appeals v. Feldman, 460 U.S. 462 (Rooker-Feldman bars federal review of state court decisions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (clarifying application of Rooker-Feldman doctrine)
- Stump v. Sparkman, 435 U.S. 349 (judicial immunity attaches even for acts alleged to be in excess of jurisdiction or malice)
- Forrester v. White, 484 U.S. 219 (judicial immunity protects from suit, not just liability for damages)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards require more than threadbare recitals)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plaintiff must allege sufficient factual matter to state a claim)
- Simmons v. Poe, 47 F.3d 1370 (requirements for civil conspiracy claim under §1985)
- Jordahl v. Democratic Party of Va., 122 F.3d 192 (Rooker-Feldman bars matters inextricably intertwined with state court judgment)