Peter Lynch v. Kathryn Donnelly

CourtCourt of Appeals for the Third Circuit
DecidedJanuary 15, 2026
Docket24-3347
StatusUnpublished

This text of Peter Lynch v. Kathryn Donnelly (Peter Lynch v. Kathryn Donnelly) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Peter Lynch v. Kathryn Donnelly, (3d Cir. 2026).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ________________

No. 24-3347 ________________

PETER J. LYNCH, Appellant

v.

KATHRYN ANNE DONNELLY, In her official capacity as Virgin Islands Special Designated Disciplinary Counsel, and in her Individual Capacity; TANISHA BAILEY- ROKA, in her Official Capacity as Virgin Islands Chief Disciplinary Counsel, and in her Individual Capacity _____________

On Appeal from the District Court for the Virgin Islands (D.C. Civil No. 3:24-cv-00043) District Judge: Honorable Mark A. Kearney ________________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) on December 9, 2025

Before: HARDIMAN, BIBAS, and PORTER, Circuit Judges

(Filed: January 15, 2026)

_______________

OPINION* _______________

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. PORTER, Circuit Judge.

Peter Lynch, a lawyer licensed to practice in the Virgin Islands, is facing ongoing

attorney disciplinary proceedings. He filed a lawsuit alleging that those proceedings

violated his constitutional rights. The District Court dismissed Lynch’s claims, finding

that it must abstain under Younger and that defendants were entitled to quasi-judicial

immunity. For the reasons below, we will affirm the District Court’s judgment.

I

Peter Lynch is a citizen of Florida and an attorney barred in the Virgin Islands.

The Office of Disciplinary Counsel (ODC) opened an investigation into Lynch for

improper solicitation of clients in violation of the Virgin Islands Rules of Professional

Conduct. Chief Disciplinary Counsel Tanisha Bailey-Roka initiated the investigation and

assigned it to Special Designated Disciplinary Counsel Kathryn Anne Donnelly. After a

great deal of back-and-forth correspondence and proceedings before the Virgin Islands

Supreme Court and the Professional Responsibility Board, Lynch sued Donnelly and

Bailey-Roka in the District Court of the Virgin Islands. The investigation remained

ongoing.

Lynch brought three claims against Bailey-Roka and Donnelly, seeking damages

and injunctive relief under (1) the All Writs Act, (2) 42 U.S.C. § 1983, and (3) 42 U.S.C.

§ 1985. Bailey-Roka and Donnelly moved to dismiss Lynch’s claims for lack of subject

matter jurisdiction, insufficient process and service of process, and failure to state a

claim. The District Court denied the motion on the first two grounds before finding that it

must abstain under Younger v. Harris, 401 U.S. 37 (1971) and that quasi-judicial

2 immunity attached to Bailey-Roka and Donnelly. Lynch v. Donnelly, 2024 WL 4819452,

at *6-14 (D.V.I. Nov. 18, 2024). Lynch timely appealed.

II 1

On appeal, Lynch argues that the District Court wrongly abstained under Younger,

mistakenly found Bailey-Roka and Donnelly entitled to quasi-judicial immunity, and

erred in denying his motion to amend the complaint. We address each issue in turn.

A

Younger requires federal courts to “abstain from deciding cases that would

interfere with certain ongoing state proceedings.” Malhan v. Sec’y U.S. Dep’t of State,

938 F.3d 453, 461 (3d Cir. 2019). Younger applies only to “three exceptional categories”

of cases: “(1) ongoing state criminal prosecutions; (2) certain civil enforcement

proceedings; and (3) pending civil proceedings involving certain orders uniquely in

furtherance of the state courts’ ability to perform their judicial functions.” Id. (quoting

Sprint Commc’ns, Inc. v. Jacobs, 571 U.S. 69, 78–79 (2013)) (quotations omitted). The

Virgin Islands calls its attorney disciplinary proceedings sui generis, but sometimes treats

them as quasi-criminal. See In re Burns, 73 V.I. 600, 610 (2020). For a court to abstain

1 The District Court had jurisdiction under 28 U.S.C. § 1331. We have jurisdiction under 28 U.S.C. § 1291. We exercise plenary review over a district court’s “determination of whether Younger abstention is proper.” Smith & Wesson Brands, Inc. v. Att’y Gen. of N.J., 27 F.4th 886, 890 (3d Cir. 2022). We apply de novo review to a district court’s order granting immunity from suit, Trinh v. Fineman, 9 F.4th 235, 237 n.1 (3d Cir. 2021), and from an order denying leave to amend on the grounds of futility. U.S. ex rel. Schumann v. Astrazeneca Pharm. L.P., 769 F.3d 837, 849 (3d Cir. 2014).

3 under Younger when an attorney disciplinary proceeding is at issue, the Court must also

find that three supplemental conditions are present, regardless of how it is categorized.

See Middlesex Cnty. Ethics Comm. v. Garden State Bar Ass’n, 457 U.S. 423, 433–34

(1982). Specifically, the proceedings must “[1] be ongoing and judicial in nature;

[2] implicate important state interests; and [3] afford an adequate opportunity to raise

federal claims.” Borowski v. Kean Univ., 68 F.4th 844, 849 (3d Cir. 2023) (citing

Middlesex, 457 U.S. at 432). Even when all these conditions are satisfied, a court should

not abstain under Younger if it finds that “(1) the state proceedings are being undertaken

in bad faith or for purposes of harassment or (2) some other extraordinary circumstances

exist.” Schall v. Joyce, 885 F.2d 101, 106 (3d Cir. 1989).

Lynch does not dispute that the three Middlesex conditions are satisfied, but

argues that Younger abstention nonetheless does not apply because Donnelly and Bailey-

Roka’s disciplinary investigation was driven by bad faith. It is Lynch’s burden to provide

evidence that bad faith existed, Schall, 885 F.2d at 111, but he fails to meet that burden.

While Lynch alleges many grievances with the attorney disciplinary system writ large in

the Virgin Islands, they are not sufficient to establish bad faith. He argues that the

charges against him were brought “without any reasonable expectation of a valid

conviction.” Appellant’s Br. at 17. But his arguments amount only to bare allegations of

bias and animus against him by Donnelly and Bailey-Roka. And his own personal view

that his actions did not violate Virgin Islands Supreme Court Rule 211.7.3 is unsupported

by any authority. This is far from sufficient to meet the demanding requirements of the

bad faith exception to Younger, which is limited to cases “of proven harassment or

4 prosecutions undertaken by state officials . . . without hope” of success. Perez v.

Ledesma, 401 U.S. 82, 85 (1971).

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Related

Bradley v. Fisher
80 U.S. 335 (Supreme Court, 1872)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Perez v. Ledesma
401 U.S. 82 (Supreme Court, 1971)
Cleavinger v. Saxner
474 U.S. 193 (Supreme Court, 1985)
Capogrosso v. the Supreme Court of New Jersey
588 F.3d 180 (Third Circuit, 2009)
Jamila Russell v. Superior Court of the Virgin I
905 F.3d 239 (Third Circuit, 2018)
Surender Malhan v. Secretary United States Depart
938 F.3d 453 (Third Circuit, 2019)
Lan Trinh v. David Fineman
9 F.4th 235 (Third Circuit, 2021)
Sprint Commc'ns, Inc. v. Jacobs
134 S. Ct. 584 (Supreme Court, 2013)
Schall v. Joyce
885 F.2d 101 (Third Circuit, 1989)
Cheryl Borowski v. Kean University
68 F.4th 844 (Third Circuit, 2023)

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Peter Lynch v. Kathryn Donnelly, Counsel Stack Legal Research, https://law.counselstack.com/opinion/peter-lynch-v-kathryn-donnelly-ca3-2026.