Mangan v. Davis

U.S. Court of Appeals for the First Circuit
Mangan v. Davis, 84 F. App'x 104 (1st Cir. 2003)

Mangan v. Davis

Opinion

PER CURIAM.

We have reviewed the record and the parties’ submissions. We affirm the lower court’s judgment on the ground that the federal courts lack subject matter jurisdiction under the principles set out in District of Columbia Court of Appeals v. Feldman, 460 U.S. 462, 476, 103 S.Ct. 1303, 75 L.Ed.2d 206 (1983), and Rooker v. Fidelity Trust Co., 263 U.S. 413, 415-16, 44 S.Ct. 149, 68 L.Ed. 362 (1923).

Appellant Thomas M. Mangan (“Mangan”) claims that the appellees violated his constitutional rights during the proceedings before the Maine Supreme Judicial Court; that these alleged violations tainted those proceedings; and that the result of those proceedings — his disbarment — is therefore called into question. If the federal court were to exercise jurisdiction here, it effectively would be second-guessing the Maine SJC’s decision that Mangan received a fair trial and that he should be disbarred. This is precisely what Rooker-Feldman prohibits.

It does not matter to our analysis whether Mangan explicitly raised a federal constitutional claim in the state court proceedings. The relevant inquiry is not whether a particular argument was raised in the state court. Rather, the relevant inquiry is whether the constitutional chai *105 lenge is of a general nature (e.g., a claim that the rules governing disbarment proceedings violate due process), or whether, instead, it targets particular actions taken by the appellees and/or the court during the proceedings and approved of by the SJC. See generally Feldman, 460 U.S. at 486. Mangan’s claims clearly are barred by the Rooker-Feldman doctrine because he alleges that certain actions in the state court proceeding by bar counsel and by the complainant violated his constitutional rights; he does not allege that the state rules themselves are unconstitutional. Mangan’s claims are “inextricably intertwined” with the state court claims. See Sheehan v. Marr, 207 F.3d 35, 40 (1st Cir. 2000). Thus, the federal courts (other than the United States Supreme Court) may not exercise jurisdiction over those claims.

Affirmed. See 1st Cir. R. 27(c).

Reference

Full Case Name
Thomas M. MANGAN, Plaintiff, Appellant, v. J. Scott DAVIS, Et Al., Defendants, Appellees
Cited By
2 cases
Status
Published