Summary
The Second Circuit affirmed dismissal of pro se plaintiffs' § 1983 claims challenging a state court leave-to-file order in a divorce proceeding. The court held that the Anti-Injunction Act barred prospective injunctive relief against state judges, the Eleventh Amendment barred retrospective declaratory relief, and the private attorney was not a state actor under § 1983. The court declined to resolve Rooker-Feldman issues because other grounds—including absolute judicial immunity, quasi-judicial immunity, and failure to state a claim—supported dismissal.
Topics
Practice areas
Questions Presented
- Whether the Anti-Injunction Act bars the Szymoniks' requests for prospective injunctive relief against state court judges
- Whether the Eleventh Amendment bars the Szymoniks' requests for retrospective declaratory relief against state court judges
- Whether the complaint states a § 1983 claim against private attorney Keith Yagaloff
- Whether the claims against the State of Connecticut and Attorney General are barred by the Eleventh Amendment and waived on appeal
- Whether the motion for injunction argument is waived
Holdings
- The Anti-Injunction Act bars federal courts from enjoining state court proceedings unless an exception applies, and no exception applies here.
- The Eleventh Amendment bars federal courts from issuing retrospective declaratory relief against state officials for past violations of federal law.
- The complaint fails to state a claim because Yagaloff is not a state actor and the conspiracy allegations are conclusory.
- The claims are barred by the Eleventh Amendment and waived on appeal.
Key quotations
“The Anti-Injunction Act (the “Act”), 28 U.S.C. § 2283, provides such a ground. It “bars a federal court from enjoining a proceeding in state court unless that action is expressly authorized by Act of Congress, or where necessary in aid of its jurisdiction, or to protect or effectuate its judgments.”” (at 4)
“The Eleventh Amendment bars federal courts from issuing retrospective declaratory relief against state officials for past violations of federal law.” (at 5-6)
“To state a claim for § 1983 conspiracy, a plaintiff must allege “(1) an agreement between a state actor and a private party; (2) to act in concert to inflict an unconstitutional injury; and (3) an overt act done in furtherance of that goal causing damages.”” (at 7-8)
Factual background
The Szymoniks, proceeding pro se, sued state court judges, the State of Connecticut, the Attorney General, and a private attorney under 42 U.S.C. § 1983, alleging that a 2012 state court order requiring Peter Szymonik to obtain leave before filing motions in his divorce proceeding violated their constitutional rights. They also alleged that the Attorney General failed to intervene and that the private attorney conspired with the judges. The district court dismissed the complaint on multiple grounds.
Procedural history
The Szymoniks filed a federal complaint in February 2018, later amended, alleging constitutional violations by state court judges and others. The district court granted defendants' motions to dismiss on various grounds including Rooker-Feldman, Eleventh Amendment, absolute judicial immunity, quasi-judicial immunity, and failure to state a claim. The Szymoniks appealed.