Robert Grundstein, J.D. v. Maine Board of Bar Examiners, et al.

Summary

The United States District Court for the District of Maine grants the defendants’ motion to dismiss Robert Grundstein’s action concerning the embargo of his July 2021 Maine bar examination score. The court concludes that the Maine Board of Bar Examiners and its members in their official capacities are protected by sovereign immunity, and that the complaint fails to state viable personal-capacity claims. The court also addresses, in the interest of completeness, the Rooker-Feldman doctrine and claim preclusion, as well as the plaintiff’s request for mandamus relief.

Holdings

1. On a motion to dismiss, the court may consider judicially noticeable docket materials and documents central to the complaint when their authenticity is not challenged, but it may not consider new factual assertions raised for the first time in an opposition brief.
2. The Maine Board of Bar Examiners is an arm of the State of Maine, and plaintiff's claims against the Board and its members in their official capacities are barred by Eleventh Amendment sovereign immunity.
3. The complaint failed to state viable personal-capacity claims against the individual defendants.
4. The Rooker-Feldman doctrine barred plaintiff's federal challenge to the Maine Supreme Judicial Court's rejection of his $150 fee-refund claim.
5. Maine claim preclusion barred plaintiff's constitutional claims arising from the Board's embargo decision because those claims were or could have been litigated in the prior Maine state-court proceeding.
6. Plaintiff was not entitled to a writ of mandamus compelling the Board to release his bar examination score.

Questions Presented

1. Whether the Maine Board of Bar Examiners and its members in their official capacities were protected by Eleventh Amendment sovereign immunity.
2. Whether the complaint alleged viable claims against the Board members in their personal capacities.
3. Whether the Rooker-Feldman doctrine barred plaintiff's challenge to the state-court disposition of his fee claim.
4. Whether Maine claim-preclusion principles barred plaintiff's constitutional claims arising from the Board's embargo decision.
5. Whether plaintiff was entitled to an order or writ of mandamus compelling release of his bar examination score.
6. Whether the court could consider transferred docket materials and exhibits attached to defendants' motion to dismiss.

Disposition

dismissed