Grundstein v. Maine Board of Bar Examiners

CourtDistrict Court, D. Vermont
DecidedJune 10, 2025
Docket2:24-cv-00685
StatusUnknown

This text of Grundstein v. Maine Board of Bar Examiners (Grundstein v. Maine Board of Bar Examiners) is published on Counsel Stack Legal Research, covering District Court, D. Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Grundstein v. Maine Board of Bar Examiners, (D. Vt. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF VERMONT

ROBERT GRUNDSTEIN, ) ) Plaintiff, ) ) v. ) Case No. 2:24-cv-685 ) MAINE BOARD OF BAR EXAMINERS; ) MELISSA K. HANSEN; CHRISTOPHER ) K. MACLEAN; JENNIFER FERGUSON; ) TRACY B. COLLINS; JOHN P. GAUSE; ) PAUL H. MILLS; ALISON E. TOZIER; ) ANDREW F. WISCH; JOHN DAVID ) KENNEDY; J. CATHERINE CONNORS, ) ) Defendants. )

OPINION AND ORDER GRANTING DEFENDANTS’ MOTION TO DISMISS (Doc. 2) Plaintiff Robert Grundstein, a Vermont resident proceeding pro se, brings this action against the Maine Board of Bar Examiners (“Maine BBE”) and each of its members, all in their individual and official capacities. The action concerns the “embargoing” of his score on the July 2021 Maine bar examination which he alleges violates his federal constitutional rights. (Doc. 1 at 2.) Defendants move to dismiss the case under Federal Rule of Civil Procedure 12(b) on several grounds. (Doc. 2.) Plaintiff opposes the motion. (Doc. 3.) For the reasons discussed below, Defendants’ motion to dismiss is GRANTED, and the case is DISMISSED. I. Plaintiff’s Allegations and Claims Plaintiff asserts the court has federal question subject matter jurisdiction under 28 U.S.C. § 1331 and supplemental jurisdiction over Maine state law claims under 28 U.S.C. § 1367. The Complaint does not make allegations regarding personal jurisdiction or venue. Plaintiff alleges that he passed the July 2021 Maine bar exam that he took remotely from Vermont and “Maine threw out the whole thing.” (Doc. 1 at 2.) Maine BBE “embargoed Plaintiff’s score” and “will not reveal or release” it. Id. at 3. Although Plaintiff asserts Maine BBE “has not provided any evidence or conducted any noticed hearings with regard to this behavior,” he acknowledges Maine BBE “did describe a specific time during the exam at which

a reason to embargo [his score] may have occurred.” Id. Maine BBE allegedly “threw out the entire exam score despite the fact that any alleged defect may not have affected his score or that any alleged defect may have been directed towards a very small part of a very severable exam with three discreet sections.” Id. at 8. He states: “This embargo is consistent with the misplaced malevolence in Defendant’s office as administered by Melissa Hansen, director of the exam.” Id. at 3. He further alleges this “sort of bad faith has consistently been a part of transactions with the [Maine BBE] and Melissa Hansen[,] Director.” Id. at 9. Plaintiff asserts five claims. Three are based on violations of his rights under the United States Constitution including the Fifth Amendment,1 the Contracts Clause, and the Ex Post Facto

Clause. His fourth claim is for a violation of Rule 7 of the Maine Rules for Admission to the Bar. Plaintiff’s fifth claim is for civil conversion under Vermont law. As relief, Plaintiff requests: (1) “his bar score be published and known to the public and Plaintiff;” (2) “an [O]rder by which Maine is forced to remove the embargo on Plaintiff’s successful bar score so it can be used in all jurisdictions;” and (3) “other equitable and legal relief this Court finds appropriate.” (Doc. 1 at 10.)

1 42 U.S.C. § 1983 provides “a method for vindicating federal rights elsewhere conferred,” Patterson v. Cnty. of Oneida, 375 F.3d 206, 225 (2d Cir. 2004) (internal quotation marks omitted), including violations of constitutional rights, and occupies a position of primacy. II. Plaintiff’s Prior Case Against Maine BBE in this Court. Plaintiff previously brought suit against Maine BBE in this court based on the same events. See Grundstein v. Maine Bd. of Bar Examiners, Case No. 2:23-cv-177 (D. Vt. July 10, 2023). On March 28, 2024, this Court issued an Opinion and Order dismissing Plaintiff’s action against Maine BBE because, as a result of Eleventh Amendment sovereign immunity, the court

lacked subject matter jurisdiction. The court explained that Plaintiff: cannot prevail in federal court on claims asserted against the State of Maine, or its agencies such as Maine BBE, absent a waiver of sovereign immunity. Plaintiff has not pointed to any waiver of Maine’s immunity. Because Plaintiff has failed to allege such a waiver, and the court is aware of none, his claims against Maine BBE must be DISMISSED. Id. slip op. at 7 (D. Vt. Mar. 28, 2024). The court declined to grant leave to amend because it would be futile. The court explained that “better pleading could not cure the substantive defect of this court’s lack of subject matter jurisdiction over Mr. Grundstein’s claims against Maine BBE.” Id. As relevant to the current case, the court further noted: While a federal district court would have jurisdiction under 42 U.S.C. § 1983 over claims against persons exercising state authority, § 1983 does not authorize claims against a state or its agencies. Likewise, although the Ex parte Young doctrine Plaintiff cites allows claims for prospective relief against state officials in their official capacities, Plaintiff does not allege claims against a state official. Id. at 6 n.2 (internal citations omitted). Because the court lacked subject matter jurisdiction, the case was dismissed without prejudice. Judgment was entered the same day. Three days later, Plaintiff moved to reopen his case and for reconsideration which the court denied on May 3, 2024. The court explicitly warned Plaintiff “that a second action naming Maine BBE as a defendant would be inappropriate.” Id. slip op. at 2 (D. Vt. May 3, 2024). The court further advised Plaintiff “that federal law allows for venue in “a judicial district in which any defendant resides, . . . [or] a judicial district in which a substantial part of the events or omissions giving rise to the claim occurred.” Id. (internal citations omitted; omission and emphasis in original). Plaintiff did not seek to appeal but commenced this action, again naming Maine BBE as a defendant and including individual defendants, on June 21, 2024. Analysis

Courts afford pleadings filed by pro se parties “special solicitude” Ceara v. Deacon, 916 F.3d 208, 213 (2d Cir. 2019) (internal quotation marks omitted), because they generally lack “legal training and experience.” Tracy v. Freshwater, 623 F.3d 90, 101 (2d Cir. 2010). Plaintiff, however, as a formerly licensed attorney representing himself, does not fall within this general rule because “a lawyer representing himself ordinarily receives no such solicitude at all.” Id.; see also Grundstein v. Eide, 2014 WL 11462807, at *5 (D. Vt. May 15, 2014) (denying Mr. Grundstein, as a self-represented lawyer, the latitude generally granted to a pro se litigant). I. Defendants’ Motion to Dismiss A. Maine BBE

As in the first case, Maine BBE moves to dismiss Plaintiff’s claims against it contending, among other reasons, that this court lacks subject matter jurisdiction because Maine enjoys sovereign immunity with regard to suits in federal courts. See Doc. 2 at 7-9. Other than the addition of individual defendants to the caption and of a few words to a heading, Plaintiff’s current Complaint is duplicative of the Amended Complaint the court previously dismissed.

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Grundstein v. Maine Board of Bar Examiners, Counsel Stack Legal Research, https://law.counselstack.com/opinion/grundstein-v-maine-board-of-bar-examiners-vtd-2025.