Lan Trinh v. David Fineman, 9 F.4th 235

Lan Tu Trinh sued David Fineman, a receiver appointed by the Court of Common Pleas (Philadelphia County) in the dissolution of Trinh’s beauty school, alleging improper accounting and "theft" of property for her sister’s benefit.
The District Court first dismissed Trinh’s initial complaint for lack of federal jurisdiction; this Court remanded to allow amendment.
Trinh amended to assert a § 1983 claim alleging Fineman abused state power; the District Court dismissed on the ground that Fineman, as a court-appointed receiver, is entitled to quasi-judicial immunity.
On appeal the Third Circuit asked the parties to address whether any alleged acts were outside the authority conferred by the state court; the record (including the state-court opinion and hearing transcript) showed the state court approved Fineman’s expenditures and fees.
The Third Circuit concluded receivers act as an "arm of the court," are subject to the common-law/Quasi-judicial immunity when acting with court authority, and affirmed dismissal because Trinh failed to show Fineman acted beyond his authority.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court-appointed receivers are entitled to quasi-judicial immunity under § 1983	Trinh: receiver abused state power and is liable under § 1983	Fineman: as a court-appointed officer acting at the court's request, he is immune	Yes. Receivers are entitled to absolute/quasi-judicial immunity when acting pursuant to court authority
Whether Fineman’s acts alleged were outside the scope of his appointment	Trinh: alleged improper accounting, theft, and acts beyond authority	Fineman: expenditures and actions were approved or known by the state court; acted per settlement and winding-down	No. Record shows state-court approval and routine receiver actions; Trinh did not show acts outside authority
Whether plaintiff pleaded a federal question sufficient for jurisdiction	Trinh: amended complaint alleges § 1983 federal question	Fineman: immunity defeats the remedy even if jurisdiction exists	District court had § 1331 jurisdiction; dismissal proper on immunity grounds rather than lack of jurisdiction
Whether immunity applies despite alleged wrongdoing or erroneous decisions	Trinh: immunity should not shield misconduct	Fineman: immunity protects official acts except where acted in clear absence of all jurisdiction	Immunity applies even to erroneous or controversial acts unless acted in clear absence of jurisdiction

Rehberg v. Paulk, 566 U.S. 356 (U.S. 2012) (§ 1983 does not abolish common-law immunities)
Forrester v. White, 484 U.S. 219 (U.S. 1988) (judicial immunity recognized for certain official functions)
Stump v. Sparkman, 435 U.S. 349 (U.S. 1978) (judicial immunity covers all judicial acts unless in clear absence of jurisdiction)
Cleavinger v. Saxner, 474 U.S. 193 (U.S. 1985) (quasi-judicial immunity extends to officials performing judge-like functions)
Atlantic Trust Co. v. Chapman, 208 U.S. 360 (U.S. 1908) (receiver has only the powers conferred by appointment and is an officer of the court)
Russell v. Richardson, 905 F.3d 239 (3d Cir. 2018) (use a functional approach to determine quasi-judicial immunity)
Keystone Redevelopment Partners, LLC v. Decker, 631 F.3d 89 (3d Cir. 2011) (consider the official’s job function, not the particular act)
Kermit Constr. Corp. v. Banco Credito Y Ahorro Ponceno, 547 F.2d 1 (1st Cir. 1976) (receiver entitled to quasi-judicial immunity)