Richard Arnold v. Manu Melwani
680 F. App'x 600
| 9th Cir. | 2017Background
- Richard T. Arnold sued various defendants including Manu and Anita Melwani, Lawrence Teker, Robert Paul Kutz, the Superior Court of Guam, the Supreme Court of Guam, and multiple Guam judges, challenging state-court proceedings and seeking monetary relief and injunctive relief to recover funds disbursed from Guam courts.
- The district court dismissed Arnold’s claims; Arnold appealed to the Ninth Circuit. The Court of Appeals had jurisdiction under 28 U.S.C. § 1291.
- Key contested events: (1) an interpleader action and appeal concerning funds (including a disputed $35,000 held in registry), and (2) a special proceeding that confirmed an arbitration award and resulted in disbursement of approximately $428,000 to Melwani.
- Arnold raised claims against judicial officers and the Guam courts, and also sought an order directing the Superior Court of Guam to release or recover funds.
- The district court dismissed claims against judicial defendants on grounds of judicial immunity and Rooker–Feldman, and dismissed claims against the remaining defendants for lack of diversity jurisdiction (Arnold domiciled in Guam).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether judicial defendants are liable for damages or injunctive relief | Arnold contends the judges exceeded or misused authority (administrative errors, bias, failure to recuse, due process violations) so immunity should not apply | Judicial defendants invoke absolute judicial immunity for acts within judicial capacity; Rooker–Feldman bars federal review of state-court judgments | Claims against judicial defendants dismissed: judicial immunity protects them; Rooker–Feldman bars review of state judgments Arnold seeks to overturn |
| Whether Melwani had standing to appeal interpleader judgment | Arnold argues Melwani lacked an interest (was not Arnold’s surety) and thus lacked standing to appeal | Defendants point to alternative legitimate claim by Melwani as shown by Guam Supreme Court opinion | Court holds Melwani had a cognizable claim and standing to join and appeal the interpleader action |
| Whether Arnold is entitled to injunctive relief ordering return/release of funds | Arnold seeks mandatory injunction to recover $428,000 and release $35,000 in registry; argues Rooker–Feldman should not apply to him on some claims | Defendants assert Rooker–Feldman bars challenges to prior state-court rulings and that Arnold fails to show entitlement to a mandatory injunction (no clear likelihood of success or irreparable harm) | Injunction denied: Rooker–Feldman bars challenges where Arnold was a party; where not barred, Arnold failed to meet heavy burden for a mandatory injunction |
| Whether federal court had diversity jurisdiction over non-judicial defendants | Arnold invoked diversity jurisdiction | Defendants assert lack of complete diversity because both Arnold and Melwanis were domiciled in Guam | Diversity jurisdiction lacking: Arnold deemed domiciled in Guam (prior filings, residence, employment, voting); plaintiff failed to rebut presumption of prior domicile |
Key Cases Cited
- Ashelman v. Pope, 793 F.2d 1072 (9th Cir.) (judicial and judge-like officials entitled to absolute immunity for judicial acts)
- Stump v. Sparkman, 435 U.S. 349 (Sup. Ct.) (immunity inquiry focuses on whether judge acted in clear absence of all jurisdiction)
- Bradley v. Fisher, 80 U.S. (13 Wall.) 335 (U.S. 1872) (foundational principle of judicial immunity)
- Henrichs v. Valley View Dev., 474 F.3d 609 (9th Cir.) (describing Rooker–Feldman as barring federal review of state-court judgments)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Sup. Ct.) (clarified scope of Rooker–Feldman)
- Lance v. Dennis, 546 U.S. 459 (Sup. Ct.) (Rooker–Feldman does not bar actions by nonparties simply because they are in privity)
- Garcia v. Google, Inc., 786 F.3d 733 (9th Cir.) (standards and disfavor of mandatory injunctions)
- Sanchez v. Monumental Life Ins. Co., 102 F.3d 398 (9th Cir.) (party invoking diversity bears burden of proving jurisdiction)
- McNutt v. Gen. Motors Acceptance Corp., 298 U.S. 178 (Sup. Ct.) (standard that plaintiff must prove jurisdictional facts by preponderance of evidence)
- Lew v. Moss, 797 F.2d 747 (9th Cir.) (presumption of previously established domicile; burden to rebut with substantial evidence)
AFFIRMED.