Miller v. Sutton
697 F. App'x 27
| 2d Cir. | 2017Background
- Plaintiff-appellant Josephine Smalls Miller, a Connecticut attorney proceeding pro se, sued state disciplinary actors under 42 U.S.C. § 1983 alleging constitutional violations arising from three ongoing state disciplinary proceedings.
- Defendants included attorneys from the Office of Chief Disciplinary Counsel and the Connecticut Statewide Grievance Committee; the State (Attorney General) defended on appeal.
- The district court dismissed the complaint under Younger abstention, concluding federal court should not intervene in ongoing state disciplinary proceedings.
- Miller argued exceptions to Younger applied and sought federal relief; the district court found no applicable exception and dismissed.
- The Second Circuit reviewed the dismissal de novo and affirmed, agreeing Younger applies to state-initiated attorney-discipline proceedings and that Miller failed to show bad faith or extraordinary circumstances.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Applicability of Younger abstention to pending state attorney-discipline proceedings | Miller contended federal court should hear her § 1983 claims despite ongoing state proceedings | Defendants argued Younger requires abstention because the state disciplinary proceedings are ongoing and of the type Younger covers | Court held Younger applies; state disciplinary proceedings implicate the same concerns and federal court must abstain |
| Bad-faith exception to Younger | Miller argued defendants pursued proceedings with illegitimate/retaliatory motives | Defendants maintained the proceedings were initiated for legitimate purposes (referrals from state judges; probable-cause finding by grievance panel) | Court held bad-faith exception not shown; defendants had legitimate bases for proceedings |
| "Extraordinary circumstances" / immediate irreparable harm exception | Miller argued she faced immediate and irreparable harm warranting federal intervention | Defendants argued any harm was speculative and review/appeal is available in state system | Court held exceptional-circumstances exception did not apply; harm speculative and state appeal remedies adequate |
| Availability of relief in federal court while state process ongoing | Miller sought to proceed in federal court to enjoin or challenge discipline | Defendants argued federal relief would improperly interfere with ongoing state enforcement | Court affirmed dismissal of federal suit; Miller may pursue state process and its review/appeal mechanisms |
Key Cases Cited
- Younger v. Harris, 401 U.S. 37 (1971) (federal courts should abstain from interfering with certain ongoing state proceedings)
- Middlesex Cty. Ethics Comm. v. Garden State Bar Ass'n, 457 U.S. 423 (1982) (state attorney-discipline proceedings fall within Younger-type abstention)
- Sprint Commc'ns, Inc. v. Jacobs, 134 S. Ct. 584 (2013) (clarified Younger applies to certain state civil proceedings, including attorney discipline)
- Diamond "D" Constr. Corp. v. McGowan, 282 F.3d 191 (2d Cir. 2002) (standards for Younger abstention and exceptions such as bad faith and extraordinary circumstances)