Parent v. New York, 485 F. App'x 500

Koziol, a suspended attorney proceeding pro se, sues the State of New York and numerous state officials in a consolidated 42 U.S.C. §1983 action seeking declaratory relief and other relief regarding custody, support, and disciplinary processes.
The district court granted several motions to dismiss or for summary judgment, denied Koziol’s cross-motion for summary judgment, and dismissed both lead and member complaints.
The court applied Younger abstention to Koziol’s declaratory-judgment claims related to ongoing state proceedings (divorce and attorney disciplinary matter).
Koziol argues that certain defendants were not entitled to judicial immunity and that his retaliation and state-law trespass claims were inadequately pleaded or improperly dismissed.
On appeal, the Second Circuit reviews de novo the district court’s Rule 12(b)(6) and summary-judgment rulings, with no special solicitude afforded to Koziol as a pro se plaintiff.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Younger abstention forecloses the declaratory-judgment claims	Koziol asserts the state court proceedings do not merit abstention for his constitutional claims	District court properly applied mandatory Younger abstention due to ongoing state proceedings and important state interests	Affirmed Younger abstention barring declaratory claims.
Whether judicial immunity defeats Koziol’s claims against Justices acting without jurisdiction	Justices were not immune from claims involving jurisdictional defects	Judicial immunity shielded actions taken in the course of official duties	Unmeritorious; immunity maintained and dismissal proper.
Whether Koziol adequately pleaded retaliation claims against state tax agents	Retaliation claims were properly pleaded against agents	Pleadings failed to state a plausible retaliation claim	No adequate retaliation claim; properly dismissed.
Whether New Hartford notice-of-claim requirements bar the trespass claim	District court misapplied notice requirements	Notice not satisfied under Gen. Mun. Law § 50-i	Dismissal proper; notice period not met.

Younger v. Harris, 401 U.S. 37 (U.S. 1971) (mandatory abstention when state proceedings ongoing and important state interests at stake)
Elk Grove Unified Sch. Dist. v. Newdow, 542 U.S. 1 (U.S. 2004) (domestic-relations matters belong to state law and state interest acknowledged)
Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423 (U.S. 1982) (state-professional conduct proceedings fall within state-regulation interest)
Hansel v. Town Court, 56 F.3d 391 (2d Cir. 1995) (state court review is adequate for Younger abstention purposes)
Liberty Mut. Ins. Co. v. Hurlbut, 585 F.3d 639 (2d Cir. 2010) (application of abstention doctrine in this circuit)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (plausibility pleading standard for civil claims)
Philip Morris Inc. v. Blumenthal, 123 F.3d 103 (2d Cir. 1997) (context for abstention and state proceedings considerations)
Litwin v. Blackstone Grp., L.P., 634 F.3d 706 (2d Cir. 2011) (standard for de novo review of district court rulings on motions to dismiss/summary judgment)