Padmanabhan v. Hulka
308 F. Supp. 3d 484
D.D.C.2018Background
- Dr. Bharanidharan Padmanabhan, a Massachusetts neurologist, had his hospital privileges suspended in 2010 and his medical license revoked after BORIM proceedings culminating in a May 2017 decision; he previously litigated related claims in state and federal court.
- He brought a 180‑page federal complaint (Oct. 2017) asserting RICO, Sherman Act, fraud, tortious interference, trespass to chattels, Section 1983, and requests for declaratory and injunctive relief against 26 defendants (many previously sued).
- Defendants moved to dismiss and Padmanabhan sought entry of default against one defendant who had not appeared.
- The court evaluated motions under Rule 12(b)(6), Twombly/Iqbal plausibility standards, and considered affirmative defenses (claim preclusion, statutes of limitation, and immunity) that are ascertainable from the record.
- The court dismissed the entire complaint with prejudice: most claims were barred by claim preclusion and statutory limitations; several defendants were entitled to absolute or quasi‑judicial immunity; other individual claims failed to state a claim; the complaint also violated Rule 8 for being prolix and unintelligible.
- Plaintiff’s default motion was denied as moot and leave to amend was denied as futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Claim preclusion (res judicata) | Padmanabhan: prior suits produced no final merits bar; parties not in privity; claims differ | Defendants: prior state and federal suits involved same parties/nucleus and produced final judgments | Court: claim preclusion applies to most defendants; prior judgments final and same nucleus of operative facts — claims barred |
| Statutes of limitations (RICO, Sherman Act, torts/§1983) | Padmanabhan: discovery of fraud occurred later; revocation in 2017 resets limitations | Defendants: injuries accrued by 2011–2013; applicable 4‑ or 3‑year limitations have expired | Court: RICO and Sherman Act claims time‑barred; tort and §1983 claims time‑barred as well |
| Immunity (absolute/quasi‑judicial) | Padmanabhan: defendants’ acts were wrongful and not protected | Defendants: witnesses/board members and prosecutorial actors acted in quasi‑judicial/adjudicative roles and are immune | Court: absolute immunity for prosecutors/testifying witnesses; quasi‑judicial immunity for BORIM members bars claims against them |
| Failure to state a claim under Rule 12(b)(6) | Padmanabhan: factual allegations suffice for conspiracy, fraud, and other torts | Defendants: allegations are conclusory, threadbare, and lack plausible facts | Court: many defendant‑specific claims dismissed for failing plausibility test (Twombly/Iqbal) |
| Complaint sufficiency (Rule 8) | Padmanabhan: identifies core claims in a short statement | Defendants: complaint is verbose, repetitive, and unintelligible | Court: complaint violates Rule 8 — is unduly prolix and burdensome; dismissal warranted |
| Motion for default against non‑appearing defendant | Padmanabhan: requests entry of default for lack of appearance | Defendants/Court: affirmative defenses (res judicata and statute) and record permit dismissal | Court: default motion denied as moot; claims against that defendant dismissed sua sponte as precluded |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for Rule 12(b)(6))
- Ashcroft v. Iqbal, 556 U.S. 662 (clarifies that legal conclusions need not be accepted at pleading stage)
- Agency Holding Corp. v. Malley‑Duff & Assocs., Inc., 483 U.S. 143 (civil RICO limitations rule)
- Rotella v. Wood, 528 U.S. 549 (accrual/discovery rule for RICO limitations)
- Zenith Radio Corp. v. Hazeltine Research, Inc., 401 U.S. 321 (antitrust accrual rule)
- Van de Kamp v. Goldstein, 555 U.S. 335 (absolute immunity for prosecutorial‑type functions)
- Bettencourt v. Bd. of Registration in Med. of Com. of Mass., 904 F.2d 772 (quasi‑judicial immunity for board members)
- Grella v. Salem Five Cent Sav. Bank, 42 F.3d 26 (issue preclusion/collateral estoppel)