Mitchell v. Fishbein
2004 WL 1728004, 377 F.3d 157 (2004)
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Rule of Law:
The Rooker-Feldman doctrine does not bar federal courts from reviewing decisions of a state administrative body, even if court-affiliated, when its actions are administrative rather than judicial. Similarly, members of such an administrative body are not entitled to absolute quasi-judicial immunity when their function is not comparable to that of a judge and is not integrally related to a specific judicial proceeding.
Facts:
- Stephen T. Mitchell, an African-American attorney, was a member of the First Department's 18-B Panel, which consists of attorneys certified to provide compensated legal representation to indigent criminal defendants.
- The Central Screening Committee (the "Committee"), whose members are the defendants, was created by the Appellate Division, First Department, to screen and certify attorneys for this panel.
- Mitchell had a successful record, including trying over 20 felony cases, and had been on the 18-B Panel since 1995.
- In 1997 or 1998, Mitchell applied for recertification to the panel.
- During the application process and in an interview, Mitchell complained that the administration of the Assigned Counsel Plan was infected with racism, specifically against African-American attorneys and their clients.
- By letter dated March 18, 1998, the Committee denied Mitchell's application for recertification and terminated his appointment to the panel.
- The Committee's letter gave no reason for the decision, stating only that it was 'final' following a 'thorough and careful review.'
Procedural Posture:
- Stephen T. Mitchell filed a pro se complaint in the United States District Court for the Southern District of New York against members of the Central Screening Committee (the 'State Defendants').
- Mitchell alleged claims under 42 U.S.C. §§ 1981 and 1983 for racial discrimination and retaliation.
- The State Defendants moved to dismiss the complaint under Fed. R. Civ. P. 12(b)(1) for lack of subject matter jurisdiction and 12(b)(6) for failure to state a claim.
- The district court granted the motion to dismiss, finding that the defendants were entitled to absolute immunity and that the court lacked subject matter jurisdiction under the Rooker-Feldman doctrine.
- Mitchell, the plaintiff-appellant, appealed the district court's judgment to the United States Court of Appeals for the Second Circuit.
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Issue:
Do the Rooker-Feldman doctrine and the principle of absolute quasi-judicial immunity bar a federal lawsuit brought under 42 U.S.C. § 1983 against members of a court-affiliated screening committee for allegedly terminating an attorney's certification to an indigent defense panel based on race and retaliation?
Opinions:
Majority - Kearse, Circuit Judge
No, neither the Rooker-Feldman doctrine nor absolute immunity bars the federal lawsuit. The Rooker-Feldman doctrine is inapplicable because it only bars federal district court review of state-court judgments, not decisions by state administrative agencies. The Screening Committee acts as an administrative body, not a judicial one, because its power is not inherent to the judiciary, its certifications are not essential for a court to appoint counsel, and its decisions concern eligibility for future compensation, which is a legislative function. The Committee's decision was not judicial in nature; it was a legislative-style declaration about rights that may arise in the future, not a ruling on an existing controversy. Likewise, the Committee members are not entitled to absolute quasi-judicial immunity. Their role is not 'functionally comparable' to a judge's, as their process lacks fundamental judicial safeguards like an adversarial process, precedent, and meaningful appellate review. Furthermore, their actions are not 'integrally related' to a specific judicial proceeding; rather, they perform the administrative task of creating a general list of attorneys for potential future appointments, which is a ministerial function.
Analysis:
This decision clarifies the limits of judicial-like protections for non-judicial actors operating within the court system. It establishes that court-affiliated committees performing administrative or gatekeeping functions, such as certifying attorneys, cannot use the Rooker-Feldman doctrine or absolute immunity to shield themselves from federal civil rights litigation. This ensures an avenue for accountability for alleged constitutional violations like racial discrimination by preventing such bodies from being treated as courts themselves. The ruling reinforces the distinction between administrative/ministerial acts (even when performed by judges or their delegates) and core judicial, adjudicative acts, which are the sole province of these protective doctrines.
