Stoddard v. Carlin
799 F. Supp. 2d 57
D.D.C.2011Background
- Stoddard sought admission to the DC Bar; COA denied certification due to character and fitness issues.
- Plaintiff previously pursued Florida Bar admission; FBBE objected and opened investigation.
- Plaintiff filed suit in 2010 against DC admissions officials, DC Court of Appeals, judges, and his ex-spouse.
- COA reported findings in 2010; DC Court of Appeals denied admission in 2010; stay lifted and amendments allowed.
- Court considers motions to dismiss for lack of jurisdiction and failure to state a claim; grants all.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether court has personal jurisdiction over Ells | Ells caused injury via letters; Maryland resident. | Ells lacked DC contact and no tort within DC. | Lack of personal jurisdiction over Ells; motion granted. |
| Whether Reid, Fisher, and Pryor are absolutely immune | Judicial officials should not be immune in these claims. | They acted within official judicial capacity and are immune. | They are shielded by absolute judicial immunity; claim dismissed. |
| Whether COA, Carlin, and Kent are shielded by quasi-judicial absolute immunity | COA officials can be sued for damages. | Bar admissions functions are quasi-judicial and immune. | Entitled to quasi-judicial absolute immunity; claim dismissed. |
| Whether the remaining defendants fail to state a claim due to immunity | Immunity not applicable to all allegations. | Immunity applies to the asserted actions. | Dismissal for failure to state a claim based on immunity. |
Key Cases Cited
- Moncrief v. Lexington Herald-Leader Co., 631 F.Supp.772 (D.D.C.1985) (outside-DC act cannot create jurisdiction when no DC act occurs)
- Simons v. Bellinger, 643 F.2d 774 (D.C.Cir.1980) (CUPL absolute immunity; arm of the court analogy)
- Butz v. Economou, 438 U.S. 478 (U.S.198 etc) (harms of litigation; safeguards and immunity factors)
- Forrester v. White, 484 U.S. 219 (U.S.1988) (judicial immunity aims to shield decisions from harassment)
- Wagshal v. Foster, 28 F.3d 1249 (D.C.Cir.1994) (three-factor test for quasi-judicial immunity)
- Malley v. Briggs, 475 U.S. 335 (U.S.1986) (complaining-witness doctrine; immunity nuances)
- Kennedy v. Educ. Testing Serv., Inc., 393 A.2d 523 (D.C.1978) (review mechanisms for bar admissions)
- Harper v. D.C. Comm. on Admissions, 375 A.2d 25 (D.C.1977) (review procedure in bar admissions process)
- Ex Parte Secombe, 60 U.S. 9 (U.S.1856) (courts’ supervisory role in admissions)
- Gustave-Schmidt v. Chao, 226 F.Supp.2d 191 (D.D.C.2002) (incorporation of documents in motion-to-dismiss review)