Mehta v. Attorney Registration & Disciplinary Commission of the Supreme Court
2012 U.S. App. LEXIS 11263
| 7th Cir. | 2012Background
- Mehta sued the Illinois Supreme Court, the ARDC, and a Review Board under 42 U.S.C. § 1983 alleging due-process violations from a suspension order.
- The Administrator filed a disciplinary complaint in 2008 alleging real-estate escrow misappropriation (> $100,000) and misrepresentation to a court.
- A Hearing Board found violations and recommended disbarment; the matter proceeded before the Commission’s Review Board.
- Before final disposition by the Review Board, the Illinois Supreme Court issued a Rule 774(a) suspension order against Mehta, effective immediately per Rule 774 and Rule 771(a).
- The Supreme Court later disbarred Mehta in a separate proceeding after the Rule 774 suspension, but the federal suit was filed while the Rule 774 suspension was still in effect; the district court dismissed under Rooker-Feldman.
- Mehta argues the Rule 774 suspension was not a final judgment and thus not barred by Rooker-Feldman; the district court and court of appeals denied this, and Mehta sought relief in federal court.
- The Seventh Circuit held that Illinois law treats an interim Rule 774 suspension as a final judgment for purposes of Rooker-Feldman, and that the earlier final judgment barred the federal suit.
- Mehta’s additional amendment request to add individual defendants was deemed futile for jurisdictional purposes since the central claim remained a challenge to the Illinois Supreme Court’s judgment.
- The disposition affirmed the district court’s dismissal under Rooker-Feldman.
- Mehta’s sole recourse would have been a petition for certiorari to the U.S. Supreme Court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the Rule 774 suspension is a final state judgment for Rooker-Feldman purposes. | Mehta contends the suspension was interim and not final. | Illinois law treats interim suspensions as final judgments in Rule 774 proceedings. | Yes; final under Illinois law, bars federal suit. |
| Whether amendment to add defendants could cure jurisdictional issues. | Amendment would cure jurisdictional defects. | Amendment would be futile; claims still review the state court judgment. | Futile; amendment would not restore jurisdiction. |
| Whether Mehta's suit falls under Rooker-Feldman despite caselaw on finality. | Finality misunderstood; suit not barred. | Rooker-Feldman bars suits challenging state-court judgments. | Rooker-Feldman bars the suit. |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Supreme Court, 2005) (applies Rooker-Feldman to state-court judgments challenged in federal court)
- United States v. Kashamu, 656 F.3d 679 (7th Cir. 2011) (state-law finality governs finality for purposes of review)
- U.S. Gypsum Co. v. Ind. Gas Co., 350 F.3d 623 (7th Cir. 2003) (finality determined by state law in connection with Rooker-Feldman)
- Skinner v. Switzer, 131 S. Ct. 1289 (Supreme Court, 2011) (finality and review logistics discussed in Rooker-Feldman context)
- Kan. City S. Ry. Co. v. Koeller, 653 F.3d 496 (7th Cir. 2011) (certiorari route for state-law defect claims after adverse judgments)