Susan N. Patrick v. Jonathan Brogan, et al.

CourtDistrict Court, D. Maine
DecidedMarch 26, 2026
Docket2:25-cv-00048
StatusUnknown

This text of Susan N. Patrick v. Jonathan Brogan, et al. (Susan N. Patrick v. Jonathan Brogan, et al.) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Susan N. Patrick v. Jonathan Brogan, et al., (D. Me. 2026).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MAINE

SUSAN N. PATRICK, ) ) Plaintiff, ) ) v. ) No. 2:25-cv-00048-JAW ) JONATHAN BROGAN, et al., ) ) Defendants. ) ORDER ON PENDING MOTIONS An inactive attorney proceeding pro se filed a complaint against an attorney and their law firm for wrongful use of civil proceedings. The defendant attorney and law firm moved to dismiss the complaint and for sanctions. The court grants the motion to dismiss, because a state court’s prior adjudication of the complaint’s allegations precludes their re-litigation in this action and the complaint fails to state a valid claim for wrongful use of civil proceedings. As sanction for filing her complaint, the court orders the inactive pro se attorney to pay the defendants’ attorney’s fees. The court also strikes her complaint and brief in opposition. I. BACKGROUND A. Procedural History On February 25, 2025, Susan Patrick, an inactive attorney, filed a pro se complaint against Norman Hanson & DeTroy LLC (NHD) and one of NHD’s members, Attorney Jonathan Brogan, (Defendants) alleging wrongful use of civil proceedings arising from Defendants’ alleged conduct as opposing counsel in a separate pro se medical malpractice suit filed by Ms. Patrick and her husband against Defendants’ client. Compl. for Wrongful Use of Civil Proceedings (ECF No. 1) (Compl.).1 In response, Defendants filed two motions. First, on April 3, 2025, Defendants

moved to dismiss the complaint for failure to state a claim. Mot. to Dismiss of Defs. Jonathan Brogan and Norman, Hanson & DeTroy, P.A., LLC (ECF No. 10) (Mot. to Dismiss). Second, on April 16, 2025, Defendants filed a motion for sanctions against Ms. Patrick. Defs. Jonathan Brogan’s and Norman Hanson & DeTroy’s Mot. for Sanctions Against Pl. (ECF No. 11) (Mot. for Sanctions). On April 21, 2025, Ms. Patrick filed her response, opposing Defendants’ motions to dismiss and for sanctions.

Pl.’s Opp’n to Two Defs.’ Mot. to Dismiss and for Sanctions (ECF No. 12) (Pl.’s Opp’n). On April 30, 2025, Defendants filed their reply in support of their motions to dismiss and for sanctions. Defs. Jonathan Brogan’s and Norman Hanson & DeTroy’s Reply Mem. in Supp. of Their Mots. to Dismiss and for Sanctions Against Pl. (ECF No. 13) (Defs.’ Reply). On September 2, 2025, this matter was reassigned to this Judge. B. The Allegations in Susan Patrick’s Complaint Ms. Patrick’s complaint alleges Defendants, in their role as opposing counsel

in Ms. Patrick’s pro se medical malpractice suit, committed the tort of wrongful use of civil proceedings by allegedly raising a baseless counterclaim accusing Ms. Patrick of fraud. Compl. ¶ 8. Ms. Patrick alleges that Defendants knew there was no evidence to support their fraud counterclaim and that they failed to withdraw the counterclaim after depositions and trial further demonstrated no evidence supported

1 The complaint initially named Medical Mutual Insurance Company (MMIC), but Ms. Patrick later voluntarily dismissed MMIC as a defendant. Deletion of Def. MMIC as a Def. (ECF No. 16). their allegation, resulting in the state court ultimately entering judgment in favor of Ms. Patrick on Defendants’ fraud counterclaim. Id. ¶ 9-12. Ms. Patrick seeks $6 million in compensatory damages, as well as punitive damages and litigation costs.

Id. at 5-6; id. ¶ 15. II. THE PARTIES’ POSITIONS A. Defendants’ Motion to Dismiss Defendants move to dismiss the complaint, arguing that Ms. Patrick’s claim “is precluded and is patently meritless.” Mot. to Dismiss at 2. Defendants argue Ms. Patrick’s claim is collaterally estopped because the parties fully litigated the issue to

final judgment in state court, concluding with the Maine Law Court considering and rejecting Ms. Patrick’s claim that Defendants lacked a factual basis or proper purpose in asserting their fraud counterclaim. Id. at 8-9. Defendants also move to dismiss on the grounds that the complaint fails to state a claim for wrongful use of civil proceedings because Ms. Patrick’s “allegations are conclusory, and the actual facts – which appear only in the state court records attached to her Complaint – affirmatively disprove her claim.” Id. at 10-14. Finally, Defendants signaled their

intent to move for sanctions in accordance with Federal Rule of Civil Procedure 11 at the appropriate time. Id. at 14 n.7. B. Defendants’ Motion for Sanctions Defendants ask this Court to sanction Ms. Patrick because, as a former attorney, she knew or should have known that her assertion is collaterally estopped and meritless, particularly given the state court previously sanctioned Ms. Patrick for pressing the same claim in the underlying state proceedings. Mot. for Sanctions at 2-6. Defendants explain that, prior to filing their sanctions motion, they provided Ms. Patrick notice of their intent to seek sanctions if she did not voluntarily dismiss

her complaint and, twenty-one days after Ms. Patrick did not respond or withdraw her complaint, they filed their motion for sanctions. Id. at 6. Defendants ask this Court to order Ms. Patrick to pay their costs, expenses, and attorney’s fees incurred in defending against the complaint, and for any additional sanctions the Court deems appropriate under the circumstances. Id. at 6. C. Susan Patrick’s Opposition to Defendants’ Motions

In opposition to Defendants’ motion to dismiss, Ms. Patrick argues that her complaint sufficiently pleads a new claim of wrongful use of civil proceedings that is not subject to res judicata and survives Rule 12(b)(6). Pl.’s Opp’n at 1-5. For that same reason, Ms. Patrick explains, sanctions against her are also unwarranted. Id. at 4-5. Lastly, Ms. Patrick accuses Attorney Brogan and his counsel of misconduct for the arguments and “derogatory statements” contained in their motions to dismiss and for sanctions. Id. at 4-5. In addition to urging the Court to deny Defendants’

motions to dismiss and for sanctions, Ms. Patrick asks the Court to impose “damages and sanctions for Attorneys Brogan and [his counsel].” Id. at 5. D. Defendants’ Reply In their reply, Defendants point out several arguments in their motions to dismiss and for sanctions that Ms. Patrick’s opposition fails to address, each of which Defendants argue are therefore conceded. Defs.’ Reply at 1-3. Defendants dispute whether Ms. Patrick’s complaint alleges a new claim, and that, even if her complaint did raise a new claim, it is barred by res judicata. Id. at 3-5. Defendants reiterate their argument that the complaint fails to state a claim for wrongful use of civil

proceedings. Id. at 5-6. Finally, Defendants argue that the accusations of misconduct against Attorney Brogan and his counsel contained in Ms. Patrick’s opposition should be stricken pursuant to Federal Rule of Civil Procedure 12(f). Id. at 6-7. Defendants reiterate their request to dismiss the complaint and for the Court to impose sanctions on Ms. Patrick for Defendants’ costs, expenses, and attorney’s fees incurred in defending this action, and any additional sanction the Court deems appropriate

under the circumstances. Id. at 7. III. Legal Standard For a complaint to survive a motion to dismiss under Rule 12(b)(6), it “must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). Plausible means “something more than merely possible” or “merely consistent with a defendant’s liability.” Germanowski v. Harris, 854 F.3d 68, 71-72

(1st Cir. 2017) (quotation marks and citations omitted) (first quoting Schatz v.

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Bluebook (online)
Susan N. Patrick v. Jonathan Brogan, et al., Counsel Stack Legal Research, https://law.counselstack.com/opinion/susan-n-patrick-v-jonathan-brogan-et-al-med-2026.