Richter v. Connecticut Judicial Branch
600 F. App'x 804
2d Cir.2015Background
- Pro se plaintiff Elizabeth A. Richter sued the Connecticut Judicial Branch, Judge Herbert Barall, and law firm O’Connell, Attmore & Morris, alleging ADA/§504 discrimination, Fourteenth Amendment due process violations, retaliation, and related state-law claims based on stress/anxiety impairing her court participation.
- Richter claimed the Judicial Branch failed to provide reasonable accommodations for her stress and anxiety, which impaired her ability to comprehend and participate in state-court proceedings and led to adverse judgments she seeks to overturn.
- The District Court dismissed Richter’s claims under Fed. R. Civ. P. 12(b)(6) and 12(b)(1); judgment entered March 28, 2014.
- On appeal, Richter argued the District Court erred in dismissing her statutory and constitutional claims and erred as to timeliness and disability elements.
- The Second Circuit reviewed de novo and affirmed the District Court, concluding various legal bars prevented relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial immunity for Judge Barall | Barall’s actions were wrongful and not immune | Barall’s acts were judicial, so absolutely immune | Barall entitled to absolute judicial immunity; claims dismissed |
| Timeliness re: O’Connell firm | Firm’s conduct violated statutes within limits | Claims against firm are time barred | Claims against O’Connell, Attmore & Morris are time barred |
| Retaliation against Judicial Branch | Judicial Branch retaliated for her disability-related complaints | No plausible retaliation pleaded | Retaliation claim not sufficiently pleaded; dismissed |
| ADA/§504 and Due Process claims seeking to overturn state judgments | Failure to accommodate caused invalid state judgments; federal relief available | Rooker–Feldman bars federal review of state-court judgments | Rooker–Feldman deprives district court of jurisdiction; claims barred |
Key Cases Cited
- Chambers v. Time Warner, Inc., 282 F.3d 147 (2d Cir. 2002) (standard for reviewing Rule 12(b)(6) dismissal)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading must be plausible)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (requirement that complaint permit reasonable inference of liability)
- Hoblock v. Albany Cnty. Bd. of Elections, 422 F.3d 77 (2d Cir. 2005) (jurisdictional review standard and Rooker–Feldman discussion)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (lower federal courts lack jurisdiction to review state-court judgments)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (1983) (limits on federal review of state-court decisions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (clarifying scope of Rooker–Feldman)
- Thyroff v. Nationwide Mut. Ins. Co., 460 F.3d 400 (2d Cir. 2006) (affirmation on alternative grounds is permissible)