Guarino v. Larsen

Summary

The court denied defendants’ motion under Federal Rule of Civil Procedure 62(c) to suspend pending appeal an injunction requiring the reinstatement of Judge Guarino to senior-judge status. It concluded that defendants had not shown a likelihood of success on the merits, irreparable injury absent a stay, or that the public interest favored suspension of the injunction.

Holdings

1. A stay pending appeal was unwarranted because defendants failed to carry their burden on each of the four stay factors.
2. The Rooker-Feldman doctrine did not bar federal jurisdiction because Justice Larsen's order removing Guarino was an administrative, non-adjudicative act rather than a state-court adjudication.
3. Younger abstention was inapplicable because the challenged removal was an administrative act and there was no ongoing judicial proceeding in which Guarino had an adequate opportunity to raise his constitutional claims.
4. Judge Guarino possessed a constitutionally protected property interest in his senior-judge assignment and could not be suspended, removed, disciplined, or compulsorily retired without due process.

Questions Presented

1. Whether defendants were entitled under Federal Rule of Civil Procedure 62(c) to suspend the district court's injunction pending appeal.
2. Whether defendants had shown a strong likelihood of success on appeal concerning the district court's jurisdiction under the Rooker-Feldman doctrine.
3. Whether Younger abstention required the district court to refrain from exercising jurisdiction.
4. Whether Judge Guarino lacked a constitutionally protected property interest in his senior-judge assignment.
5. Whether the remaining stay factors—irreparable injury to defendants, substantial harm to Guarino, and the public interest—favored suspension of the injunction.

Disposition

other