Langadinos v. Washington State Bar Association

CourtDistrict Court, W.D. Washington
DecidedMarch 15, 2024
Docket2:23-cv-00250
StatusUnknown

This text of Langadinos v. Washington State Bar Association (Langadinos v. Washington State Bar Association) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Langadinos v. Washington State Bar Association, (W.D. Wash. 2024).

Opinion

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3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 GREGORY LANGADINOS, CASE NO. 2:23-cv-250 8 Plaintiff, ORDER GRANTING IN PART, AND 9 DENYING IN PART DEFENDANTS’ v. MOTIONS TO DISMISS 10 WASHINGTON STATE BAR 11 ASSOCIATION, WASHINGTON STATE BAR ASSOCIATION BOARD 12 OF GOVERNORS, LISA AMATANGEL, Associate Director; 13 Litigation and Internal Operations, JULIE SHANKLAND, Coordinator; 14 ADA/504 WSBA, WASHINGTON STATE SUPREME COURT, 15 Defendants. 16

17 1. INTRODUCTION 18 In response to the COVID-19 pandemic and civil rights protests following the 19 murder of George Floyd, the Washington State Supreme Court waived the bar exam 20 requirement for graduates of accredited law schools who were registered by the 21 appropriate cutoff to take the July or September 2020 bar exams. This has been 22 23 1 called the “diploma privilege” option for admission to the Washington State Bar 2 Association (WSBA) and the practice of law in Washington.

3 Plaintiff Gregory Langadinos, proceeding pro se,1 sues the State Supreme 4 Court, the WSBA, and others, seeking admission to the Washington bar and 5 damages—in sum, he argues he was denied the diploma privilege because of his 6 disabilities. Both Defendants move to dismiss his complaint for lack of jurisdiction. 7 Dkt. Nos. 10, 11. The Court has reviewed the papers submitted in support of and in 8 opposition to the motions, and finds that oral argument is unwarranted. For the

9 reasons explained below, the Court GRANTS in part and DENIES in part 10 Defendants’ motions to dismiss. 11 2. BACKGROUND 12 The Court accepts all facts as true from the complaint and construes them in 13 the light most favorable to Langadinos. Fed. R. Civ. P. 12(b)(6). 14 Langadinos, a California resident, earned a juris doctor degree from the 15 Appalachian School of Law on May 8, 2004. Dkt. No. 1 ¶¶ 6, 36; see also Dkt. No. 1

16 at 100. The complaint is silent, however, about whether Langadinos has been 17 admitted to a state bar since his graduation or otherwise engaged in the practice of 18 law. See generally id. 19 On consecutive days from March 3 to March 6, 2020, Langadinos “repeatedly 20 attempted to apply over the internet to register” and pay for the July 2020 bar exam 21 1 In his complaint, Langadinos states he is proceeding pro se until the Court rules 22 on his California attorney’s application for leave to appear pro hac vice and to waive Local Civil Rule 83.1(d). Dkt. No. 1 ¶ 2. But to date, no attorney has appeared on 23 Langadinos’s behalf. See Dkt. 1 on the WSBA’s website. Id. ¶ 24. He alleges the website was not working properly 2 and that it repeatedly rejected his completed applications. Id. ¶ 25. Langadinos has

3 “thyroid eye disease, exophthalmos” and a “neurogenic bladder disorder,” which 4 prevent him “from staring at a computer screen for an extended period of time.” Id. 5 According to Langadinos, the WSBA’s website, however, did not offer “Job Access 6 with Speech” or “other computer applications for visually impaired applicants.” Id. 7 ¶ 5. By his estimate, Langadinos called the WSBA about eight times to report that 8 its website “was not working properly.” Id. ¶ 28.

9 Langadinos also mailed and faxed a letter to Gus Quinones, the WSBA’s 10 Admissions Manager, on March 27, 2020, requesting an accommodation for his 11 disabilities. Id. ¶ 30. In his letter, Langadinos explained that his medical treatment 12 and “neurogenic bladder disorder requiring [him] to catheterize and suffer pain 13 throughout the day[,]” made it “very inconvenient” to spend multiple hours a day 14 trying “to access the web site without any progress” and, as a reasonable 15 accommodation, he requested “to receive a hard copy application” for the July 2020

16 bar exam. Dkt No. 1 at 29-31. The WSBA did not respond to Langadinos’s letter. Id. 17 ¶ 31. 18 On June 12, 2020, the State Supreme Court issued an order modifying the 19 Washington Admission and Practice Rules (APR) 3 and 4. The order granted 20 applicants the option of receiving a diploma privilege to practice in Washington so 21 long as they were already registered to take the July or September 2020 bar

22 examination and they received a Juris Doctorate from an ABA accredited law 23 school. Id. ¶ 33; see also id. at 53-54. 1 Langadinos was not registered to take the 2020 bar examination when the 2 State Supreme Court instituted the diploma privilege. Langadinos contacted the

3 court about his failed attempts to register. Specifically, “[d]uring the week of June 4 15, 2020,” Langadinos contacted Lisa Armstrong, the State Supreme Court’s 5 Administrative Coordinator. Dkt. No. 1 at 70 ¶ 9. At some point, he also wrote the 6 State Supreme Court. See id. ¶ 53. 7 On June 25, 2020, Chief Justice Debra Stephens emailed Langadinos. She 8 began by saying, “[t]hank you for your email and letter requesting an expansion of

9 the Diploma Privilege to your circumstances . . . .” Id. at 50. And ended by saying, 10 “[t]he balance of interests counsels against further modification of the court’s order, 11 though I appreciate this is disappointing to you, and your circumstances are 12 unfortunate.” Id. at 51. 13 For the next several weeks, Langadinos communicated with multiple WSBA 14 staff members, asking that he be granted the diploma privilege given his failed 15 attempts to register—through no fault of his own, he alleges—and unanswered

16 reasonable accommodation request. On June 26, 2020, Langadinos spoke to the 17 WSBA Associate Director for Regulatory Affairs, Robert W. Henry. Dkt. No. 1 18 ¶¶ 38, 40-42. On July 3, 2020, Langadinos spoke with WSBA General Counsel Jean 19 McElroy. Id. ¶ 44. In an email, McElroy requested further evidence of Langadinos’s 20 prior registration attempts in March, April, and May 2020. Id. at 42. 21 On August 3, 2020, Langadinos’s then-attorney, James Neyman, submitted a

22 “formal petition” for diploma privilege via “first class U.S. mail as well as email” to 23 Lisa Amatangel, Associate Director for Litigation and Internal Operations for the 1 Office of General Counsel. Id. at 60-67. The WSBA maintained that Langadinos was 2 ineligible for diploma privilege under State Supreme Court’s order. Id. at 75.

3 Langadinos also contacted the Clerk’s Office of the State Supreme Court on 4 September 1, 2020. Dkt. No. 1 at 90. In response, a clerk wrote that “by court rule, 5 the administration of the bar examination is delegated to the WSBA” and “[t]here is 6 no process for appealing such individual determinations [about accommodations] to 7 the Supreme Court.” Id. at 89. 8 On February 23, 2023, Langadinos filed a complaint, alleging WSBA and the

9 State Supreme Court violated Title II of the Americans with Disabilities Act (ADA), 10 the Rehabilitation Act of 1973, the Washington Law Against Discrimination 11 (WLAD), and the Fourteenth Amendment. Id. ¶¶ 48-105. Langadinos further 12 alleges the state-law claim of intentional infliction of emotional distress. Id. ¶¶ 106- 13 111. 14 3. DISCUSSION 15 3.1 Legal standards. 16 3.1.1 Rule 12(b)(1). 17 The Court must dismiss a complaint under Rule 12(b)(1) if it lacks subject 18 matter jurisdiction. Thus, an action will be dismissed if it (1) does not arise under 19 the Constitution, laws, or treaties of the United States, or falls outside one of the 20 other enumerated categories of Article III, Section 2, of the Constitution; (2) is not a 21 case or controversy within the meaning of the Constitution; or (3) is not one 22 described by any jurisdictional statute. See Baker v. Carr, 369 U.S. 186, 198 (1962).

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Langadinos v. Washington State Bar Association, Counsel Stack Legal Research, https://law.counselstack.com/opinion/langadinos-v-washington-state-bar-association-wawd-2024.