MADRIGAL v. ZUNIGA
1:16-cv-09415
D.N.J.Oct 23, 2017Background
- Plaintiff Celso Laredo Madrigal, a New Jersey state prisoner, filed a civil rights action on December 21, 2016 without paying the filing fee or filing a complete IFP application.
- The Court terminated the action conditionally, allowing reopening if Madrigal paid the fee or submitted a complete IFP application and gave leave to amend to cure jurisdictional defects.
- Madrigal later submitted a proper IFP application; the Court granted in forma pauperis status.
- The Court conducted screening under 28 U.S.C. §§ 1915(e)(2)(B) and 1915A and found the original complaint failed to state a cognizable § 1983 claim against defense attorneys.
- The Court also found it lacked federal jurisdiction to enforce an arbitration award from the New Jersey Fee Arbitration Committee (no federal-question jurisdiction under the FAA and no diversity jurisdiction).
- The Court dismissed the § 1983 claims with prejudice and dismissed the arbitration-enforcement claim for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether IFP application should be granted | Madrigal sought to proceed without prepayment of fees | N/A (no opposition noted) | IFP application granted under 28 U.S.C. § 1915(a) |
| Whether defense attorneys are state actors under § 1983 | Madrigal sued defense attorneys under § 1983 | Defense counsel are not state actors (public or private defense counsel) | Dismissed with prejudice: defense attorneys are not state actors |
| Whether the FAA provides independent federal-question jurisdiction to enforce a state arbitration award | Plaintiff sought federal enforcement of a NJ Fee Arbitration Committee award under the FAA | FAA does not create independent federal-question jurisdiction; no diversity jurisdiction or requisite amount in controversy | Dismissed for lack of subject-matter jurisdiction |
Key Cases Cited
- Newton v. City of Wilmington, [citation="676 F. App'x 106"] (3d Cir. 2017) (public or private defense counsel are not state actors for § 1983)
- Polk County v. Dodson, 454 U.S. 312 (U.S. 1981) (public defenders are not state actors under § 1983)
- Steward v. Meeker, 459 F.2d 669 (3d Cir. 1972) (privately-retained defense counsel not state actors)
- Goldman v. Citigroup Global Markets, Inc., 834 F.3d 242 (3d Cir. 2016) (FAA does not by itself create federal-question jurisdiction)
- Moses H. Cone Memorial Hospital v. Mercury Construction Co., 460 U.S. 1 (U.S. 1983) (overview of federal arbitration law principles)