Sinapi v. RI Board of Bar Examiners, 910 F.3d 544

Anthony Sinapi, who has ADHD and anxiety, requested testing accommodations (extra time, reduced-distraction room, permission for medication) for the July 2015 Rhode Island bar exam; Rhode Island Board of Bar Examiners denied the request citing insufficient medical documentation.
Sinapi filed an emergency petition to the Rhode Island Supreme Court; the Chief Justice denied emergency relief but ordered disclosure of the Board's independent medical evaluation.
Sinapi then sued the Board in federal district court the day the Chief Justice ruled, seeking monetary damages under federal law and a TRO ordering the requested accommodations; the district court granted a TRO the day before the exam.
Sinapi sat for the exam with limited accommodations (25% extra time, distraction-reduced room); he later failed that sitting but passed on a subsequent attempt with 50% extra time.
The district court later dismissed Sinapi’s amended complaint (monetary claims) based on Eleventh Amendment and quasi-judicial immunity, but awarded Sinapi attorneys’ fees for obtaining the TRO; the First Circuit reversed the fee award and affirmed the dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Sinapi was a "prevailing party" under the ADA for fee-shifting	Sinapi argued his TRO obtaining accommodations made him a prevailing party eligible for fees	Board argued the TRO was preliminary and Sinapi never prevailed on the merits, so no fees	Reversed: TRO alone (without merits victory) did not make Sinapi a prevailing party for fees
Whether district court had jurisdiction under Rooker–Feldman	Sinapi contended federal court could hear claims despite state-court action	Board argued Rooker–Feldman barred federal review of state-court denial	Court avoided resolving Rooker–Feldman, deciding on merits issues instead (outcome would be same)
Whether Eleventh Amendment bars monetary damages against the Board/official-capacity defendants	Sinapi argued Title II/§1983 claims could proceed	Board argued it is an arm of the state and immune unless Congress validly abrogated immunity for actual Fourteenth Amendment violations	Affirmed: Claims against the Board/official-capacity members barred by Eleventh Amendment because no alleged actual Fourteenth Amendment violation
Whether individual Board members are liable for damages or immune	Sinapi challenged individual liability for denying accommodations	Board argued quasi-judicial (and alternatively qualified) immunity protects members for adjudicatory acts	Affirmed: Members enjoy quasi-judicial immunity from damages claims arising from adjudicative denial of accommodations

Rooker v. Fidelity Trust Co., 263 U.S. 413 (prohibits lower federal courts from reversing state-court judgments)
D.C. Court of Appeals v. Feldman, 460 U.S. 462 (limits federal jurisdiction over state-court decisions)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (clarifies Rooker–Feldman scope)
Buckhannon Bd. & Care Home v. W. Va. Dep’t of Health & Human Res., 532 U.S. 598 (prevailing party requires judicially sanctioned change in legal relationship)
Sole v. Wyner, 551 U.S. 74 (preliminary relief alone does not confer prevailing-party status when merits later fail)
Race v. Toleda-Davila, 291 F.3d 857 (1st Cir.) (fees not warranted where only preliminary relief obtained)
Bettencourt v. Bd. of Registration in Med. of Com. of Mass., 904 F.2d 772 (1st Cir.) (framework for quasi-judicial immunity for agency decisionmakers)
Tennessee v. Lane, 541 U.S. 509 (Eleventh Amendment and circumstances for abrogation by Section 5 of the Fourteenth Amendment)
United States v. Georgia, 546 U.S. 151 (Congress may abrogate Eleventh Amendment for actual Fourteenth Amendment violations)
Butz v. Economou, 438 U.S. 478 (scope of immunity for officials performing adjudicatory functions)
Cleveland Bd. of Educ. v. Loudermill, 470 U.S. 532 (due-process standards for public employment deprivation)