Ricky Kamdem-Ouaffo v. Vincent Leblon
673 F. App'x 223
| 3rd Cir. | 2016Background
- Kamdem-Ouaffo, a flavor/aroma developer, sued Hill’s Pet Nutrition in New Jersey state court in 2013 for trade-secret misappropriation; discovery completed and Hill’s moved for summary judgment in June 2015.
- Kamdem-Ouaffo filed a notice of removal to federal court on August 14, 2015 (docketed Aug. 21); he did not appear at the Aug. 20 state-court hearing claiming the removal divested the state court of jurisdiction.
- The New Jersey state court (Judge Vincent Leblon) granted summary judgment for the defendants and ordered certain documents sealed; the federal district court later remanded the case to state court on Sept. 29, 2015.
- Kamdem-Ouaffo then sued under 42 U.S.C. § 1983 naming his former state-court attorneys, the defendants’ attorneys, and Judge Leblon, alleging a conspiracy to violate his due-process rights (entering judgment despite removal and reliance on forged/sealed documents).
- The district court dismissed the amended § 1983 complaint under Rule 12(b)(6); Kamdem-Ouaffo appealed. The Third Circuit affirms dismissal and denies leave to amend as futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether federal court can review and set aside the adverse state-court judgment (Rooker–Feldman) | Kamdem-Ouaffo sought to overturn the state-court judgment as injurious | Defendants argued federal court lacks jurisdiction to review final state-court judgments under Rooker–Feldman | Claims seeking to set aside the state judgment are barred by Rooker–Feldman |
| Whether defendants (private attorneys) are state actors for § 1983 liability | Kamdem-Ouaffo alleged conspiracy between attorneys and the judge, pointing to meetings and adverse ruling as evidence | Defendants argued private attorneys are not state actors and conspiracy allegations are conclusory | Private attorneys are not state actors; conspiracy allegations were implausible and dismissed |
| Whether Judge Leblon is liable under § 1983 for actions at the hearing | Kamdem-Ouaffo asserted the judge violated his due-process right (e.g., ruling despite removal notice) | Defendants invoked absolute judicial immunity for judicial acts | Judge Leblon immune: granting summary judgment and sealing records are judicial acts entitled to absolute immunity |
| Whether amendment or other relief should be permitted (e.g., Rule 59(e) issues) | Kamdem-Ouaffo sought leave to amend and moved under Rule 59(e) | District court denied amendment and Rule 59(e); defendants opposed | Denial of leave to amend affirmed as amendment would be futile; district-court denial of Rule 59(e) not before the court on appeal |
Key Cases Cited
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility standard for complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (conclusory allegations insufficient)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (Rooker–Feldman doctrine)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal courts lack jurisdiction to review state-court judgments)
- Great W. Mining & Mineral Co. v. Fox Rothschild LLP, 615 F.3d 159 (scope of Rooker–Feldman and conspiracy pleading standard)
- Kach v. Hose, 589 F.3d 626 (§ 1983 requires state action)
- Angelico v. Lehigh Valley Hosp., Inc., 184 F.3d 268 (private attorneys generally not state actors)
- Stump v. Sparkman, 435 U.S. 349 (absolute judicial immunity for judicial acts)