Riley v. Louisiana State Bar Ass'n

214 F. App'x 456
CourtCourt of Appeals for the Fifth Circuit
DecidedJanuary 19, 2007
Docket06-30695
StatusUnpublished
Cited by3 cases

This text of 214 F. App'x 456 (Riley v. Louisiana State Bar Ass'n) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Riley v. Louisiana State Bar Ass'n, 214 F. App'x 456 (5th Cir. 2007).

Opinion

*457 PER CURIAM: *

Plaintiff-Appellant Michael J. Riley, Sr. (“Riley”) appeals the district court’s granting of Defendants-Appellees Louisiana State Bar Association’s (“Bar Association”) and Louisiana Attorney Disciplinary Board’s (“Board”) (collectively, “Defendants”) motions to dismiss. 1 Specifically, Riley argues that the district court erred in holding that: (1) the Eleventh Amendment barred Riley’s claims for monetary damages against the Bar Association and the Board, 2 and (2) it lacked jurisdiction to hear Riley’s claims under the Rooker-Feldman doctrine. We decline to reach the Eleventh Amendment issues. However, we agree with the district court that the Rooker-Feldman doctrine deprives it of jurisdiction to hear any of Riley’s claims. We therefore AFFIRM.

I. FACTUAL AND PROCEDURAL HISTORY

In 2003, Riley sought readmission to the Louisiana State Bar Association for the third time. The Louisiana Supreme Court denied Riley’s application for readmission on November 19, 2004. In re Riley, 887 So.2d 459 (La.2004), reconsideration denied, 898 So.2d 1286 (La.2005). In response, Riley requested reconsideration of that decision, which the Louisiana Supreme Court denied. Riley then petitioned the United States Supreme Court for a writ of certiorari, which was also denied.

Despite these setbacks, Riley remained undeterred. On June 20, 2005, Riley filed a complaint in the United States District Court for the Eastern District of Louisiana against the Bar Association and the Board, alleging violations of the Fourteenth Amendment due process and equal protection clauses in addition to 42 U.S.C. §§ 1981, 1983, and 1988 et seq. Riley alleges that the Board libeled him by submitting recommendations to the Louisiana Supreme Court which stated that Riley had not completed all court-ordered restitution. Compl. XXI. Riley contends that the Louisiana Supreme Court denied his application for readmission because of the allegedly false claims in the Board’s recommendations. Id. XXV. Riley further contends that the Bar Association and the Board treat black applicants for readmission differently than they treat white applicants. Id. XXXIX-XXXXIV. The complaint seeks both injunctive relief and monetary damages.

The Bar Association and the Board filed separate motions to dismiss under Rule 12(b)(6). In separate orders, the district court granted both motions for substantially the same reasons. Riley now appeals those orders.

II. JURISDICTION AND STANDARD OF REVIEW

Riley appeals the district court’s orders granting Defendants’ motions to dismiss, *458 so this court has jurisdiction to hear the appeal under 28 U.S.C. § 1291.

This court reviews a Rule 12(b)(6) motion to dismiss de novo. United States ex rel. Willard v. Humana Health Plan of Texas Inc., 336 F.3d 375, 379 (5th Cir. 2003). We must accept all well-pleaded facts as true and review the complaint in the light most favorable to the plaintiff. Id. We may dismiss a claim if the plaintiff fails to allege any set of facts in support of his claim which would entitle him to relief. Id.

III. DISCUSSION

The district court determined that Riley was not entitled to relief because the Eleventh Amendment and the Rooker-Feldman doctrine barred Riley’s claims against the Defendants. The district court held that Eleventh Amendment immunity shielded the Defendants from suit for monetary damages. Further, the district court held that, under the Rooker-Feldman doctrine, it lacked jurisdiction over all of Riley’s claims, including those for declaratory and injunctive relief. Because, under the Rooker-Feldman doctrine, we may legitimately decide this case exclusively on jurisdictional grounds, we decline to reach any Eleventh Amendment issues. 3

The Rooker-Feldman doctrine directs that federal district courts lack jurisdiction to entertain collateral attacks on state court judgments. Liedtke v. State Bar of Tex., 18 F.3d 315, 317 (5th Cir.1994). State courts should resolve constitutional questions arising from state proceedings. Id. “If a state trial court errs[,] the judgment is not void, it is to be reviewed and corrected by the appropriate state appellate court. Thereafter, recourse at the federal level is limited solely to an application for a writ of certiorari to the United States Supreme Court.” Id. “A federal complainant cannot circumvent this jurisdictional limitation by asserting claims not raised in the state court proceedings or. claims framed as original claims for relief.” United States v. Shepherd, 23 F.3d 923, 924 (5th Cir.1994). Similarly, a federal complainant cannot re-litigate issues that should have been raised in state court and defeat the operation of the Rooker-Feldman doctrine by casting a complaint as a civil rights violation. Liedtke, 18 F.3d at 317. Finally, Rooker-Feldman bars federal claims which, while not identical to, are “inextricably intertwined” with state court judgments. Id. at 318.

Riley argues that Rooker-Feldman does not apply to his case. Instead, he contends that his complaint states a separate cause of action unrelated to his application for readmission to the bar. Riley cites to our decisions in Davis v. Bayless, 70 F.3d 367 (5th Cir.1995), and Gauthier v. Continental Diving Services, Inc., 831 F.2d 559, 561 (5th Cir.1987), for the proposition that Rooker-Feldman does not bar an action in federal court if the same action would be allowed in the state court of the rendering state.

Riley’s arguments are unavailing. Riley attempts to frame the alleged violations of his civil rights as original claims, but they arise from, and exist only because of, the Louisiana Supreme Court’s denial of his application for readmission.

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Bluebook (online)
214 F. App'x 456, Counsel Stack Legal Research, https://law.counselstack.com/opinion/riley-v-louisiana-state-bar-assn-ca5-2007.