United States v. Mohammad Alkaramla
2017 U.S. App. LEXIS 18455
| 7th Cir. | 2017Background
- CJA-appointed attorney Philip Bernstein hired forensic expert Erich Speckin without obtaining the district court’s required preapproval for CJA-funded experts.
- Speckin billed $15,142.90, far exceeding the CJA $2,400 cap; Bernstein submitted a CJA voucher six months after his client was sentenced.
- The district judge refused to approve the voucher at that amount; Bernstein took no immediate action in federal court.
- Speckin sued Bernstein in Michigan state court for breach of contract; the state court entered a default judgment against Bernstein.
- Bernstein returned to the federal district court seeking (1) vacatur or an injunction against enforcement of the state-court judgment, (2) an order requiring Speckin to release claims, and (3) payment to Speckin from CJA funds; the district court denied relief and Bernstein appealed.
Issues
| Issue | Bernstein's Argument | Speckin/Federal Court's Argument | Held |
|---|---|---|---|
| Whether district court has jurisdiction to vacate or enjoin state-court judgment | CJA supervisory authority over appointment/payment of experts supports federal jurisdiction | No federal statute authorizes review of state judgments; dispute is private contract governed by state law | No jurisdiction; dismissal required |
| Whether All Writs Act authorizes relief | All Writs Act permits federal courts to issue necessary writs in aid of jurisdiction | The Act does not confer independent jurisdiction — it only aids an existing jurisdiction | All Writs Act unavailable because no underlying federal jurisdiction exists |
| Whether Rooker–Feldman/28 U.S.C. § 1257 preclude district-court review | Bernstein sought federal relief from state judgment (argues federal supervisory role) | Rooker–Feldman bars lower federal courts from reviewing state court judgments | Relief seeking to vacate state judgment is barred by Rooker–Feldman |
| Whether Anti‑Injunction Act bars an injunction or order directing Speckin to release claims | Bernstein sought injunction of enforcement and direction that Speckin release state claims | Anti‑Injunction Act forbids stays of state-court proceedings or injunctions against enforcement except narrow exceptions, none apply | Anti‑Injunction Act bars requested relief; also too late to seek CJA disbursement |
Key Cases Cited
- Stearnes v. Baur’s Opera House, Inc., 3 F.3d 1142 (7th Cir. 1993) (federal courts must confirm subject-matter jurisdiction)
- Kokkonen v. Guardian Life Ins. Co. of Am., 511 U.S. 375 (U.S. 1994) (federal courts have limited, statutory jurisdiction)
- Lambert v. Buss, 498 F.3d 446 (7th Cir. 2007) (All Writs Act does not create jurisdiction)
- Brokaw v. Weaver, 305 F.3d 660 (7th Cir. 2002) (Rooker–Feldman bars lower federal court review of state judgments)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (Supreme Court exclusive authority over state-court judgments review)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (limits on lower federal-court review of state bar/licensing decisions)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (U.S. 2005) (clarifies Rooker–Feldman scope)
- Mains v. Citibank, N.A., 852 F.3d 669 (7th Cir. 2017) (whether requested relief is tantamount to vacating state judgment)
- Pelfresne v. Village of Williams Bay, 865 F.2d 877 (7th Cir. 1989) (Anti‑Injunction Act prohibits injunctions against state proceedings)
- Adkins v. Nestlé Purina PetCare Co., 779 F.3d 481 (7th Cir. 2015) (narrow scope of exception to Anti‑Injunction Act for aiding federal jurisdiction)
Decision: Vacated the district court’s order and remanded with instructions to dismiss Bernstein’s motion for lack of subject-matter jurisdiction.