Neroni v. Zayas, 663 F. App'x 51

Plaintiff Frederick J. Neroni, a disbarred attorney appearing pro se, sued under 42 U.S.C. § 1983 challenging his state-court disbarment, New York unauthorized-practice-of-law (UPL) statutes, and denial of access to his disciplinary file.
The district court dismissed the complaint for lack of jurisdiction and failure to state a claim; it also denied Neroni’s motion to recuse the district judge.
Neroni appealed the dismissal and the denial of recusal to the Second Circuit.
The central factual posture: Neroni lost his disciplinary proceedings in New York state court and then filed the federal suit seeking review and relief from those state proceedings and related state-law restrictions on his activities.
The Second Circuit reviewed jurisdictional dismissals and judgment on the pleadings de novo and recusal denial for abuse of discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rooker‑Feldman bars federal review of Neroni’s challenge to his disbarment	Neroni argued his disbarment and related rulings should be reviewable in federal court and were not purely judicial/administrative	Defendants argued Rooker‑Feldman bars federal review of state‑court judicial decisions, including attorney discipline	Held: Rooker‑Feldman applies; challenges to disbarment are barred because attorney discipline is a judicial power and Neroni lost in state court
Whether challenges to NY UPL statutes are justiciable (ripeness / pre‑enforcement challenge)	Neroni claimed UPL provisions unlawfully restrict his speech, teaching, and writing about law	Defendants argued Neroni lacks a well‑founded fear of prosecution and claims are not prudentially ripe	Held: Claims non‑justiciable. Neroni failed to show a well‑founded fear of enforcement and failed prudential ripeness analysis
Whether the district judge should have recused	Neroni asserted bias, citing adverse rulings and prior related litigation involving his wife	Defendants contended adverse rulings do not establish judicial bias	Held: No abuse of discretion; Neroni did not establish bias — rulings against him are insufficient

L-7 Designs, Inc. v. Old Navy, 647 F.3d 419 (2d Cir. 2011) (standards for judgment on the pleadings)
Jaghory v. N.Y. State Dep’t of Educ., 131 F.3d 326 (2d Cir. 1997) (jurisdiction and failure‑to‑state standard review)
Vossbrinck v. Accredited Home Lenders, Inc., 773 F.3d 423 (2d Cir. 2014) (Rooker‑Feldman doctrine formulation)
Verizon Maryland, Inc. v. Pub. Serv. Comm’n, 535 U.S. 635 (2002) (distinguishing judicial from executive/administrative actions for Rooker‑Feldman)
Mitchell v. Fishbein, 377 F.3d 157 (2d Cir. 2004) (attorney discipline characterized as judicial action for Rooker‑Feldman purposes)
Zimmerman v. Grievance Comm. of the Fifth Judicial Dist. of the State of New York, 726 F.2d 85 (2d Cir. 1984) (Rooker‑Feldman applies to attorney disciplinary orders)
Nat’l Org. for Marriage v. Walsh, 714 F.3d 682 (2d Cir. 2013) (ripeness/prudential ripeness framework)
MedImmune, Inc. v. Genentech, Inc., 549 U.S. 118 (2007) (pre‑enforcement challenges and well‑founded fear standard)
Hedges v. Obama, 724 F.3d 170 (2d Cir. 2013) (requirement to show enforcement is likely in pre‑enforcement challenges)
In re Basciano, 542 F.3d 950 (2d Cir. 2008) (recusal standard; adverse rulings alone do not prove bias)