Judy Thorpe v. State of New Jersey
677 F. App'x 46
| 3rd Cir. | 2017Background
- Judy Thorpe, pro se, appealed the District Court of New Jersey's dismissal of her employment-discrimination complaint and initially failed to pay the appellate filing fee; the Third Circuit reopened the appeal and granted IFP.
- Thorpe sought "judicial review" of two adverse New Jersey state-court employment decisions that had already been resolved on direct and post‑appeal review.
- The District Court dismissed the complaint, concluding it lacked jurisdiction under the Rooker‑Feldman doctrine to the extent Thorpe sought review of state‑court judgments.
- Thorpe also alleged (1) violations of the Civil Service Reform Act (CSRA) and (2) that state‑court defendants lied and manipulated procedural/evidentiary rules; the District Court did not separately treat these vague claims as federal causes of action.
- The Third Circuit reviewed de novo, found the appeal timely, agreed Rooker‑Feldman barred review of claims that effectively sought reversal of state judgments, and affirmed for alternative reasons as to any non‑Rooker‑barred claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal courts have jurisdiction over claims that seek review of state‑court judgments (Rooker‑Feldman) | Thorpe sought judicial review of adverse state‑court employment rulings in federal court | District Court: Rooker‑Feldman bars federal review of injuries caused by state‑court judgments | Held: Rooker‑Feldman applies; district court lacked jurisdiction to the extent the complaint invited review/rejection of state judgments |
| Whether Thorpe's appeal was timely | Thorpe filed notice of appeal within 180 days after an order that included reasons (argued timely) | Appellee suggested possible untimeliness | Held: Appeal was timely because the District Court's order contained reasoning and the notice was filed within the 180‑day LeBoon period |
| Whether alleged CSRA claims state a federal cause of action | Thorpe alleged discrimination and illegal job action under CSRA | Defendants: CSRA protects federal employees; Thorpe is not a federal employee | Held: CSRA claim frivolous — Thorpe did not allege status as a federal employee; claim fails |
| Whether vague allegations of lies/manipulation in state proceedings amount to federal claims or require amendment | Thorpe alleged state‑court parties lied and manipulated rules | District Court declined to parse or permit amendment given vagueness and conclusory nature | Held: No reversible error in dismissing these vague/conclusory allegations; amendment not required under circumstances |
Key Cases Cited
- Turner v. Crawford Square Apartments III, L.P., 449 F.3d 542 (3d Cir. 2006) (standards for reviewing dismissal under Rooker‑Feldman)
- LeBoon v. Lancaster Jewish Cmty. Ctr. Ass’n, 503 F.3d 217 (3d Cir. 2007) (when a separate Rule 58 document is required, 180‑day appeal period applies if none exists)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (federal courts lack jurisdiction to review final state court judgments)
- District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (limits on federal district court review of state judicial decisions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (Rooker‑Feldman scope and narrow application)
- Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159 (3d Cir. 2010) (Rooker‑Feldman requires the injury to be produced by the state‑court judgment)
- Elgin v. Department of the Treasury, 567 U.S. 1 (2012) (CSRA provides exclusive remedy for federal employment disputes)