Guarino v. Larsen

11 F.3d 1151 (3d Cir. 1993) · United States Court of Appeals for the Third Circuit · November 30, 1993

Summary

The United States Court of Appeals for the Third Circuit held that the Rooker-Feldman doctrine deprived the federal district court of subject-matter jurisdiction over Angelo Guarino's constitutional challenge to the Pennsylvania Supreme Court's revocation of his senior-judge assignment. The court concluded that the Pennsylvania Supreme Court's subsequent order adjudicated Guarino's state-law property claim and was sufficiently intertwined with his due-process claim. It vacated the district court's injunction and remanded with instructions to dismiss the action.

Holdings

  1. The November 10, 1992 order, considered in isolation, was administrative or ministerial rather than adjudicative, but the March 10, 1993 order applied Pennsylvania law and adjudicated Guarino's legal claim concerning his right to senior-judge status. The combined state-court actions therefore triggered Rooker-Feldman.
  2. Rooker-Feldman barred the property-based due process claim because the March 1993 Pennsylvania Supreme Court order decided that Guarino had no state-law property right to senior-judge status, making the federal constitutional claim inextricably intertwined with the state-court decision.
  3. Guarino waived his liberty-based due process claim by failing to attempt to present it at the Pennsylvania Supreme Court's show-cause hearing.
  4. Younger abstention did not apply because the state proceedings had been completed before the district court acted on the merits and no state proceeding remained pending for the federal court to enjoin.

Questions Presented

  1. Whether the Pennsylvania Supreme Court's November 1992 and March 1993 orders constituted an adjudication triggering the Rooker-Feldman jurisdictional bar.
  2. Whether Guarino's property-based due process claim was inextricably intertwined with the state court's determination that he had no property right to senior-judge assignments.
  3. Whether Guarino waived his liberty-based due process claim by failing to present it at the Pennsylvania Supreme Court's show-cause hearing.
  4. Whether Younger abstention applied to the federal action.

Disposition

vacated

Cases Cited (13)

  • Younger v. Harris, 401 U.S. 37, 41-42, 91 S.Ct. 746, 750, 27 L.Ed.2d 669 (1971)(distinguished)
  • Blake v. Papadakos, 953 F.2d 68, 71, 73 (3d Cir. 1992)(followed)
  • District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 468, 472, 477, 479-83 & n. 16 (1983)(followed)
  • Rooker v. Fidelity Trust Co., 263 U.S. 413, 414, 416, 44 S.Ct. 149, 150, 68 L.Ed. 362 (1923)(followed)
  • Valenti v. Mitchell, 962 F.2d 288, 296 (3d Cir. 1992)(followed)
  • Prentis v. Atlantic Coast Line, 211 U.S. 210, 226, 29 S.Ct. 67, 69, 53 L.Ed. 150 (1908)(followed)
  • In re Summers, 325 U.S. 561, 568-69, 65 S.Ct. 1307, 1312, 89 L.Ed. 1795 (1945)(followed)
  • Marbury v. Madison, 5 U.S. (1 Cranch) 137, 177, 2 L.Ed. 60 (1803)(followed)
  • Gibson v. Berryhill, 411 U.S. 564, 93 S.Ct. 1689, 36 L.Ed.2d 488 (1973)(distinguished)
  • Pennzoil Co. v. Texaco, 481 U.S. 1, 15, 107 S.Ct. 1519, 1528, 95 L.Ed.2d 1 (1987)(followed)

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