Michael Vincent Clinger v. Linda A. Cartisano, et al.

Summary

The Eastern District of Pennsylvania dismissed Michael Vincent Clinger’s federal complaint against judges, court administrators, private attorneys, a corporation, and other defendants. The court held that the Rooker-Feldman doctrine deprived it of subject matter jurisdiction, that certain judicial and administrative defendants were immune from suit, and that the federal claims were inadequately pleaded. The court declined supplemental jurisdiction over the state-law claims and dismissed the action with prejudice.

Holdings

1. The Rooker-Feldman doctrine barred the federal court from exercising subject-matter jurisdiction because Clinger was a state-court loser complaining of injuries caused by a prior state-court judgment and seeking relief that would require review, rejection, or interference with that judgment.
2. The Judicial Defendants, Judges Linda A. Cartisano and John J. Whelan, were entitled to judicial immunity and could not be sued for actions taken while presiding over the state-court dispute, even if those actions were erroneous, malicious, or in excess of authority.
3. The Administrative Defendants were immune from suit because Pennsylvania state courts and their agencies are protected by Eleventh Amendment immunity and court administrators performing activities integral to the judicial process receive quasi-judicial immunity.
4. Clinger failed to state a § 1983 due-process claim because the Judicial and Administrative Defendants were immune and the remaining private defendants were not plausibly alleged to have acted under color of state law.
5. Clinger failed to state a § 1985(3) conspiracy claim because he did not allege discriminatory animus against an identifiable class or invidious discrimination, relying instead on conclusory allegations of conspiracy.
6. Clinger failed to state a § 1986 neglect-to-prevent claim because the claim was asserted against defendants who were immune from suit.
7. The court declined to exercise supplemental jurisdiction over Clinger's remaining Pennsylvania state-law claims after dismissing all federal claims within its original jurisdiction.
8. The complaint was dismissed with prejudice because amendment would be futile.

Questions Presented

1. Whether the Rooker-Feldman doctrine deprived the federal court of subject-matter jurisdiction over claims seeking relief from injuries allegedly caused by a prior state-court judgment.
2. Whether the Judicial Defendants were entitled to judicial immunity.
3. Whether the Administrative Defendants were entitled to Eleventh Amendment or quasi-judicial immunity.
4. Whether Clinger plausibly stated claims under 42 U.S.C. §§ 1983, 1985(3), and 1986.
5. Whether the court should exercise supplemental jurisdiction over the remaining Pennsylvania state-law claims.

Disposition

dismissed