39 F. Supp. 3d 11
D.D.C.2014Background
- WPA sues under 42 U.S.C. § 1983 against DC Court of Appeals judges Thompson, Beckwith, Nebeker, and DC Superior Court judges Hedge, Rankin, plus Scherlis defendants.
- Defendants move to dismiss for lack of subject matter jurisdiction, failure to state a claim, and Younger abstention.
- WPA claims due process violations arising from proceedings in landlord-tenant and damages cases spanning 1994–2012.
- Key events include a 2005 default judgment in the landlord-tenant case, its vacatur, consolidation of cases, remand by the DC Court of Appeals, and partial summary judgment for Scherlis in the damages case.
- WPA seeks declaratory relief and an injunction delaying the damages case until the DC Court of Appeals decides the related appeal.
- Court grants in part and denies in part: Rooker-Feldman does not bar the action; injunctive relief is dismissed; declaratory relief remains, and Younger abstention does not apply.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does Rooker-Feldman bar WPA’s §1983 action? | WPA argues interlocutory state-court review is reviewable in federal court. | Doctrine bars review of state-court judgments or their functional equivalents. | Rooker-Feldman does not bar suit; state proceedings had not ended. |
| Whether WPA states a claim for injunctive relief under §1983 | Seeks an injunction to halt further proceedings until appeal is decided. | Judicial immunity bars injunctive relief against judges for acts in their judicial capacity. | Injunctive relief claim dismissed due to immunity. |
| Whether declaratory relief is barred by Younger abstention | Younger applies to stay federal review of ongoing state proceedings. | District has interest in state landlord-tenant administration; federal relief inappropriate. | Younger abstention does not apply; declaratory relief remains available. |
| Whether declaratory relief is available given potential appellate avenues | No higher DC authority exists to review the DC Court of Appeals’ handling of the appeal. | WPA could seek certiorari or continue through existing appellate avenues. | Declaratory relief not unavailable; courts may still adjudicate. |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (limits Rooker-Feldman to final state-court judgments and certain pre-final circumstances)
- Richardson v. Dist. of Columbia Court of Appeals, 83 F.3d 1513 (D.C. Cir. 1996) (interlocutory appeals; limits of Rooker-Feldman pre-Exxon Mobil)
- Hoai v. Superior Court of the Dist. of Columbia, 539 F. Supp. 2d 432 (D.D.C. 2008) (injunctive relief against judges; declaratory relief unavailable does not apply)
- JMM Corp. v. Dist. of Columbia, 378 F.3d 1117 (D.C. Cir. 2004) (appeal avenues for correcting state-court decisions; declaratory relief possibilities)
- Federación de Maestros de Puerto Rico v. Junta de Relaciones del Trabajo de Puerto Rico, 410 F.3d 17 (1st Cir. 2005) (defines when state proceedings have ended for Rooker-Feldman purposes)