Ison v. Schulman, 2:21-cv-01546

Background

Plaintiffs James Ison and The Ison Law Firm sued after alleging a December 2020 mediation in a San Mateo personal-injury case was a "sham" and that insurer Mercury and defense counsel misrepresented attendance.
Plaintiffs filed a separate suit in San Francisco against Mercury, its counsel, and the mediator; the San Francisco court granted anti-SLAPP motions, and Judge Ethan Schulman imposed sanctions and a $5,000 contempt fine and awarded roughly $80,000 in fees to Mercury. Plaintiffs appealed those rulings.
After the state-court sanctions and rulings, Plaintiffs filed this federal suit alleging § 1983 civil-rights claims, RICO and fraud claims, and seeking declaratory and injunctive relief against Judicial Defendants (Judge Schulman, Superior Court, Judicial Council, Chief Justice Cantil‑Sakauye) and Non‑Judicial Defendants (insurer, defense counsel, mediator).
Judicial and Non‑Judicial Defendants moved to dismiss, raising Article III standing, abstention doctrines (Younger and Rooker‑Feldman), res judicata/collateral estoppel, Eleventh Amendment/state‑actor immunity, and judicial immunity.
The district court granted both motions in full, dismissing the complaint without leave to amend and ordering Plaintiffs to show cause why several unserved defendants should not be dismissed.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing to sue Chief Justice and Judicial Council	Ison contends assignment of Judge Schulman to sit temporarily on Court of Appeal creates bias and a deprivation of due process warranting federal relief	Judicial Defendants argue Plaintiffs lack Article III injury and traceability to those assignments	Dismissed for lack of Article III standing; no leave to amend
Abstention re Judge Schulman and Superior Court (Younger)	Ison seeks injunctive/declaratory relief for alleged constitutional violations by state judge	Defendants invoke Younger: federal courts must not interfere with ongoing state judicial proceedings and appeals	Dismissed under Younger; federal jurisdiction barred; no leave to amend
Immunities (Eleventh Amendment and judicial immunity)	Ison argues relief other than money is proper and declaratory/injunctive relief should be available	Defendants assert Eleventh Amendment bars suit against state actors and judges have absolute immunity for judicial acts	Claims barred by Eleventh Amendment and by absolute judicial immunity; dismissal affirmed
Jurisdiction/preclusion vs Non‑Judicial Defendants (Rooker‑Feldman and res judicata)	Ison repackages allegations as federal civil‑rights and RICO claims	Defendants say federal suit is de facto appeal of state rulings and is precluded by Rooker‑Feldman and state‑court judgments have preclusive effect	Dismissed for lack of jurisdiction (Rooker‑Feldman) and on res judicata grounds; dismissal without leave to amend

Key Cases Cited

Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (federal courts are courts of limited jurisdiction)
Summers v. Earth Island Inst., 555 U.S. 488 (standing requires concrete, imminent injury)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (plaintiff bears burden to prove standing)
Friends of the Earth, Inc. v. Laidlaw Envtl. Servs., 528 U.S. 167 (standing elements explained)
Younger v. Harris, 401 U.S. 37 (federal courts must abstain from interfering with pending state proceedings)
Pennzoil Co. v. Texaco, Inc., 481 U.S. 1 (abstention and respect for state adjudication)
Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal courts cannot act as appellate review of state court judgments)
Feldman (D.C. Court of Appeals v. Feldman), 460 U.S. 462 (limits on federal review of state court decisions)
Mireles v. Waco, 502 U.S. 9 (judicial immunity for acts within judicial jurisdiction)
Pierson v. Ray, 386 U.S. 547 (judicial immunity applies even if judge acted maliciously)
Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (Eleventh Amendment and suits against state officials)
Kentucky v. Graham, 473 U.S. 159 (Eleventh Amendment and official‑capacity suits)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for pleadings)
Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards and legal conclusions)
Cook v. Harding, 879 F.3d 1035 (Ninth Circuit articulation of Younger factors)
Moore v. Brewster, 96 F.3d 1240 (judicial immunity precludes injunctive relief against judges)