Kamasinski v. Fitzgerald, et al.

2003 DNH 121
CourtDistrict Court, D. New Hampshire
DecidedJuly 16, 2003
DocketCV-03-205-M
StatusPublished

This text of 2003 DNH 121 (Kamasinski v. Fitzgerald, et al.) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kamasinski v. Fitzgerald, et al., 2003 DNH 121 (D.N.H. 2003).

Opinion

Kamasinski v . Fitzgerald, et a l . CV-03-205-M 07/16/03 UNITED STATES DISTRICT COURT

DISTRICT OF NEW HAMPSHIRE

Theodore Kamasinski, Plaintiff

v. Civil N o . 03-205-M Opinion N o . 2003 DNH 121 Edward Fitzgerald, III, Peter W . Heed, Daniel S t . Hillaire, and Martha Van Oot, Defendants

O R D E R

Invoking the provisions of 42 U.S.C. § 1983, veteran pro se

litigant Theodore Kamasinski brings this action against New

Hampshire Superior Court Associate Justice Edward Fitzgerald,

III, New Hampshire Attorney General Peter Heed, Merrimack County

Attorney Daniel S t . Hillaire, and New Hampshire Bar Association

President Martha Van Oot, each in his or her official capacity.

Kamasinski claims that his constitutionally protected rights have

been (and/or will be) violated if this court does not intervene

to: (1) block the enforcement against him of an injunction

entered by the state superior court (which enjoined Kamasinski

from engaging in the unauthorized practice of l a w ) ; and (2)

declare that the state court’s order is “in violation of the United States Constitution and 42 U.S.C. § 1983.” Complaint at

24. 1

Each defendant moves to dismiss Kamasinski’s complaint.

Kamasinski objects.

Background

Kamasinski did not attend law school, nor is he admitted to

practice law in this or any other state. Nevertheless, he

derives at least a portion of his income by providing legal

advice and representation to citizens of New Hampshire. That

fact, particularly in light of New Hampshire’s statutory

provision barring those who are not licensed attorneys from

“commonly” engaging in the practice of law, N.H. Rev. Stat. Ann.

(“RSA”) 311:7, has prompted a fair amount of litigation in the

1 Of course, the state court’s order cannot be “in violation of” section 1983, since that statute does not vest citizens with any substantive rights. Instead, it merely provides a vehicle by which individuals may pursue civil actions against state actors for alleged violations of their federally protected statutory or constitutional rights. See, e.g., Graham v . Connor, 490 U.S. 386, 393-94 (1989) (“As we have said many times, § 1983 is not itself a source of substantive rights, but merely provides a method for vindicating federal rights elsewhere conferred.”) (citation and internal quotation marks omitted).

2 state judicial system concerning the legality of Kamasinski’s

ongoing representation of clients.

The piece of state court litigation relevant to this

proceeding was initiated in 2001. Kamasinski filed a petition

for declaratory judgment in the state superior court, asking the

court to declare that he was not engaged in the unauthorized

practice of law. Respondents (defendants in this action), New

Hampshire’s Attorney General and the state bar association

president, filed a cross-petition, seeking an order enjoining

Kamasinski from providing any legal representation or rendering

any legal services that violate RSA 311:7. See RSA 311:7-a

(authorizing the attorney general to “maintain an action for

injunctive relief in the supreme or superior court against any

person who renders, offers to render, or holds himself or herself

out as rendering any service which constitutes the unauthorized

practice of law” and also authorizing the state bar association

to intervene in that proceeding).

The procedural history of that case is described in detail

in the superior court’s order of January 3 0 , 2003. Kamasinski v .

3 McLaughlin, 2003 WL 367745 (N.H. Super. Jan. 3 0 , 2003).

Essentially, after Kamasinski repeatedly refused to comply with

discovery obligations in that case, the court granted

respondents’ motion to compel and ordered Kamasinski to produce

the requested discovery material and information. Nevertheless,

Kamasinski steadfastly refused. In pleadings filed with the

court, Kamasinski did not deny that he had failed to comply with

the court’s order. Instead, he challenged the court’s authority

to compel him to produce such discovery. Id. at *1 n.1. In

response, the court directed him to comply fully with its

discovery orders, or risk having all relevant and material facts

alleged against him deemed confessed. Kamasinski neither

complied with the order nor did he move the court to reconsider.

Id. at * 1 .

After affording Kamasinski ample time to produce the

relevant discovery materials (which he did not d o ) , the court

entered its order of January 3 0 , 2003, which is the subject of

this litigation. In i t , the court concluded that Kamasinski was

engaged in the unauthorized practice of law, in violation of RSA

4 311:7, by virtue of having commonly practiced law without a

license. Id. * 3 . The court went on to conclude that:

[E]ven if Mr. Kamasinski’s activities were protected by RSA 311:7, the Court finds that the well pleaded facts now taken as confessed establish that Mr. Kamasinski is not of good character, and thus, does not qualify to file an appearance on behalf of another pursuant to RSA 311:1.

Id. at * 4 . 2 Accordingly, the respondents’ cross-petition for

injunctive relief was granted and Kamasinski was enjoined from

engaging in the unauthorized practice of law. Among other

things, Kamasinski was enjoined from: (1) giving legal advice to

anyone; (2) filing an appearance on behalf of any litigant in a

state court or state administrative proceeding; (3) drafting or

participating in the drafting of pleadings, briefs, or memoranda

on behalf of any person other than himself; and (4) negotiating

legal rights or responsibilities on behalf of anyone other than

himself. Id. at * 5 .

2 RSA 311:1 provides that, “A party in any cause or proceeding may appear, plead, prosecute or defend in his or her proper person, that i s , pro s e , or may be represented by any citizen of good character. For the purposes of this section, a citizen shall be presumed to be of good character unless demonstrated otherwise.” (emphasis supplied).

5 Kamasinski filed a timely motion for reconsideration of that

order, which the superior court denied in an unpublished written

opinion. Kamasinski v . McLaughlin, N o . 2001-E-386 (N.H. Super.

April 1 1 , 2003). He did not, however, take an appeal to the New

Hampshire Supreme Court. Instead, on May 1 3 , 2003, he filed the

instant federal petition for declaratory and injunctive relief,

by which he seeks a judicial declaration that the state superior

court’s order of January 3 0 , 2003, enjoining him from engaging in

the unauthorized practice of law, is unconstitutional. He also

seeks a temporary and permanent injunction prohibiting defendants

from enforcing that state court order.

Discussion

Each defendant advances several grounds in support of his or

her motion to dismiss, including the Rooker-Feldman doctrine,

principles of judicial and prosecutorial immunity, abstention

doctrines, and comity. Kamasinski counters by saying none of the

familiar arguments advanced by defendants is applicable to this

particular case. He argues that this court should determine that

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