Rodriguez v. Shulman
2012 U.S. Dist. LEXIS 20882
D.C. Cir.2012Background
- Plaintiffs Isidoro and Irene Rodriguez allege a vast, multi-year conspiracy by judges, officials, and private actors across multiple courts and agencies.
- Two linchpins: Isidoro’s 2006 Virginia disbarment and the IRS’s denial of deductions on the 2006 tax return.
- Plaintiffs filed suit on June 28, 2011 and amended on October 19, 2011 with numerous counts alleging constitutional and statutory violations.
- Four groups of defendants moved to dismiss; a sanctions motion was filed by Commonwealth Defendants.
- The court grants the Motions to Dismiss as to all federal claims but denies sanctions at this stage.
- The court declines to exercise supplemental jurisdiction over remaining state-law claims and dismisses the remaining state-law claims without prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preclusion governs the federal claims? | Isidoro argues claims survive despite prior rulings. | Defendants contend claim and issue preclusion bars relitigation. | Yes; preclusion bars the challenged federal counts. |
| Do the federal claims state a claim upon which relief can be granted? | Plaintiffs allege a wide conspiracy and rights violations. | Claims fail under Twombly/Iqbal as conclusory. | Counts fail to state a claim; dismissed. |
| Are judicial or quasi-judicial defendants immune from damages claims? | Challenged actions were unconstitutional and void. | Judicial and quasi-judicial immunity applies. | Yes; claims barred by judicial/quasi-judicial immunity. |
| Can § 7214 and § 7433 claims be pursued as private actions? | IRS denial and damages under tax statutes. | §7214 has no private right; §7433 requires proper party and exhaustion. | §7214 dismissed; §7433 count dismissed without prejudice (exhaustion). |
| Should state-law claims be kept under supplemental jurisdiction? | State-law conspiracy and related claims remain. | All federal claims dismissed; no basis to retain state claims. | Decline supplemental jurisdiction; dismiss state claims without prejudice. |
Key Cases Cited
- Stump v. Sparkman, 435 U.S. 349 (U.S. 1978) (judicial immunity for acts within judicial capacity)
- Bradley v. Fisher, 80 U.S. 335 (U.S. 1872) (absolute judicial immunity for judicial acts)
- Butz v. Economou, 438 U.S. 478 (U.S. 1978) (quasi-judicial immunity for officials acting in adjudicatory capacity)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (U.S. 2007) (standard to plead plausible claims")
- Ashcroft v. Iqbal, 556 U.S. 662 (U.S. 2009) (plausibility pleading standard (Twombly-Iqbal))