Federal Complaint That Is "Inextricably Intertwined" With State Court Proceedings Is Barred
BROWN v. BOWMAN (February 2, 2012)
Bryan Brown applied for admission to the Indiana Bar in 2007. The Indiana Board of Law Examiners, which governs the Bar's admissions process, referred Brown to the Judges and Lawyers Assistance Program for evaluation. The Program assists the Board by evaluating bar applicants when asked. The Program referred Brown to a psychologist, who noted the possibility of a bipolar disorder but suggested further psychiatric testing. Brown wrote several letters expressing his concern about the political and religious content of the examinations but ultimately agreed to the psychiatric evaluation. The psychiatrist concluded that Brown suffered from a personality disorder. Brown continued his complaints to the Board and the Program, even requesting a civil rights investigation. Eventually, the Board denied Brown's application for admission. Brown requested and was granted a hearing. When the Board affirmed its decision, Brown sought and was denied reconsideration, appealed unsuccessfully to the Indiana Supreme Court, and was denied certiorari by the United States Supreme Court. He filed a multi-count federal lawsuit against various defendants, including the psychologist, the psychiatrist, and the clinical director of the Program. Brown alleged violations of the First Amendment, due process, and equal protection. Judge Springmann (N.D. Ind.) dismissed the claims on the grounds that they were barred by the Rooker-Feldman doctrine and also concluded that several individual defendants were entitled to absolute immunity. Brown appeals
In their opinion, Seventh Circuit Judges Cudahy, Kanne, and Sykes affirmed. Under the Rooker-Feldman doctrine, a lower federal court has no jurisdiction in cases that attack prior state court judgments. It applies not only when a federal court is asked to overturn a state court judgment but also where the claims are so "inextricably intertwined" with the state court proceedings that the federal court is in essence reviewing the judgment. In the latter case, the court must also determine that the plaintiff had a reasonable opportunity to raise the issues in the state court proceedings. Here, Brown does not ask the court to reverse the state court judgment but his claims do require the federal court to review the Indiana Supreme Court's proceedings. Brown made the same arguments he makes here in the state court and the state court had the power to resolve the. His claims are therefore barred under Rooker-Feldman. Given the Court's resolution of the Rooker-Feldman issue, it was unnecessary to address the immunity issue. Nevertheless, the Court expressed its opinion that the psychologist, psychiatrist, and clinical director were likely entitled to a witness' common law absolute immunity and the Director was also likely entitled to statutory immunity.
Michael Rigney practices in the law offices of GVC Ltd. in Chicago. In this blog, he reports on select