John Croley v. Joint Committee on Judicial Administration
Opinion
In 1985, John Croley brought a personal injury suit against the Republican National Committee (RNC) in the District of Columbia Superior Court after an RNC security guard physically assaulted Croley while he was photographing an overflowing dumpster near RNC headquarters.
See
Croley v. Republican Nat'l Comm.
,
Croley here sues the Joint Committee on Judicial Administration, the administrative arm of the D.C. court system, seeking compensatory and punitive damages for what he alleges was the Joint Committee's role in the events causing that thirteen-year delay in receiving his payment. After the RNC paid and counsel took their cut, Croley-suffering permanent and disabling injuries from the assault-was left unable to navigate the process of obtaining his money from the registry at the Superior Court. The money the RNC paid to satisfy the judgment was in the court's possession as of 2002 but, Croley alleges, court administrators failed to release it to him; they rebuffed his requests for assistance and for reasonable accommodations for his disabilities, and they misled him as to the funds' status. If the Joint Committee had requisite disability accommodation policies in place, Croley alleges, he would have had prompt possession of his damages award. Instead, Croley was deprived for more than a decade of funds meant to compensate him for, among other things, his lost earnings. And he spent significant time, expense, and energy over those many years in repeated, unsuccessful efforts to dislodge his judgment from the Superior Court-efforts that would have been entirely unnecessary, he contends, if the Joint Committee had fulfilled its legal obligations.
Croley, acting pro se , sued the Joint Committee in federal court for damages. He claimed that the Joint Committee violated his property rights and failed to comply with its affirmative obligations under federal law to accommodate disabled litigants. The district court sua sponte dismissed Croley's complaint for want of federal jurisdiction under the Rooker - Feldman doctrine. To the extent Croley's complaint calls for appeal of a District of Columbia court order issued in Croley's suit against the RNC, any such claim is barred by Rooker - Feldman . But Rooker - Feldman is no bar to those portions of Croley's federal complaint against the Joint Committee that do not seek to appeal orders in his Superior Court suit against the RNC: Neither Croley's claim that Superior Court administrative personnel violated his property rights by misleading him and mishandling his award, nor his claim that court administrators neglected their legal duty to make the courts accessible to persons with disabilities like his, necessarily calls for the federal courts to review any state court judgment. We therefore reverse the judgment of the district court and remand for further proceedings consistent with this opinion.
I.
In his 1985 personal injury suit, Croley established that an RNC-employed security
guard attacked him, inflicting post-traumatic stress disorder, chest trauma, and brain injuries that left him permanently disabled.
See
Croley
,
Croley filed suit against the RNC and the security guard in D.C. Superior Court. Following a seven-day trial in October 1998,
At this threshold procedural stage, we have a limited record chronicling the disconnect between Croley and the money the RNC paid to satisfy his judgment. We rely on Croley's
pro se
complaint, which we construe in the light most favorable to him,
see
Brown v. Whole Foods Mkt. Grp.
,
After successful defense of his judgment in the D.C. Court of Appeals in 2000,
see
Croley
,
The RNC in January of 2002 paid $1,367,012.37-Croley's jury award plus post-judgment interest to that date. The docket records a motion "for authority to deposit judgment proceeds into registry of court," which the court granted with the specifications that the RNC's payment satisfied the judgment and that defendants "are in no way responsible for the resolution of the fee dispute between [Croley] and [his] counsel." Appendix (App.) 87. Croley's counsel then moved to collect his fees, and the Superior Court distributed $115,579.39 to him in full satisfaction of the attorney's lien. Croley's damages apparently remained in possession of the court.
The docket reflects no further activity in Croley's Superior Court case for more than three years, at which point an entry states: "Converted Court Ordered Escrow as of May 19, 2005." App. 88. That entry records the "amount paid" as $1,251,432.98, App. 88, a sum equal to the RNC's payment minus the attorney's lien, without interest from the time the court took possession of the payment in 2002. Only a few months later, the docket states: "Unclaimed escrow funds transferred to the US Treasury on 9/27/05," with no further explanation or any suggestion that a court order directed such transfer. App. 88. The same docket entry then includes the notation "VOIDED UNDELIVERABLE." App. 88. Croley alleges that, in fact, "defendant Superior Court never conveyed plaintiff Croley's property to US Treasury," but instead "constantly possessed plaintiff Croley's property for itself, notwithstanding the misleading accounting reports and false statements of D.C. courts." Compl. ¶ 19(d) n.3.
Approximately two and a half years later, the docket shows that Croley, still acting pro se , sought possession of his money. On February 6, 2008, the Superior Court denied Croley's "Motion to Return Money Paid to Court Register." App. 88. Apparently recognizing that Croley's $1.2 million was unaccounted for, the court's order said in full:
The Court cannot discern on the motion presented that the moving party is entitled to the funds. In addition the movant represents that the Court is no longer in possession of any funds. On this motion, the Court cannot find it has jurisdiction to order any return of funds that may now be in possession of the United States Treasury.
Order Den. Pl.'s Mot. to Return Money Paid to Ct. Register, 1985-CA-2075 (Feb. 5, 2008). Croley did not appeal that order. According to the docket, activity in the case then ceased for five more years, until March 2013, when an attorney entered an appearance on Croley's behalf, only to withdraw just over a year later, with Croley still empty-handed.
Croley alleges that, all the while, he personally contacted the court repeatedly to collect his money, but administrative personnel misled him about its status and location. Compl. ¶¶ 19(d), 20. Court administrative staff, for example, "falsely advised" Croley to collect from the "Office of Unclaimed Funds," although his funds remained in the court registry. Id. ¶ 37. In his attempts to gain possession of his money, Croley also alleges that he-like other disabled litigants in the D.C. court system-was repeatedly denied disability accommodations such as extra time and easy-to-navigate procedures. Id. ¶¶ 30-31. In one such instance, Croley alleges, he asked the court's ADA coordinator to help him respond to his new attorney's 2014 withdrawal motion, but the coordinator did not "direct Plaintiff Croley to published grievance procedures" or otherwise assist him. Id. ¶ 34(c)(i).
Croley finally succeeded in bringing the matter to a head late in 2014. On September 17, Croley moved to "Restore Affirmed Judgment." App. 89. On November 24, 2014, Croley, again pro se , filed the federal suit at issue in this appeal. That same day-a dozen years after the RNC paid the judgment into the court registry and Croley first sought to collect it-the D.C. Superior Court scheduled a status hearing on the funds and issued a Notice of Intent to Release Funds, that is, to pay Croley his money. The United States and the District of Columbia responded to the D.C. Superior Court's Notice by affirmatively disclaiming any right or interest to the funds. On December 18, 2014, the court formally ordered disbursement. On January 14, 2015, nearly twenty years after he filed his personal injury suit in D.C. Superior Court and thirteen years after the D.C. Court of Appeals sustained the verdict in his favor, Croley finally received the $1,251,432.98 the court had withheld: the total of the RNC's payment minus Croley's attorney's lien, without any interest for the time the D.C. Superior Court had possession of the money.
When the Superior Court ordered the disbursement, it described Croley's case against the RNC as "closed," and the court's own authority as limited to issuing the order calling for release from the court registry. The Superior Court judge added at the hearing: "[I]f [Croley] had an issue with what the Superior Court did, then [he was] free to file a lawsuit on that. But filing it as part of this closed case was not appropriate. Because the District of Columbia Superior Court would have to be a party to that action and that party needs notice." App. 111-12.
This case seeks to hold the Joint Committee responsible for the court administration's role in the long delay Croley faced between winning his award and receiving it. The Joint Committee on Judicial Administration, composed of judges, manages general personnel policies, accounts and auditing, and procurement and disbursement for the D.C. court system.
See
Croley's
pro se
federal complaint raises two sets of claims. First, Croley claims the Joint Committee violated his property rights. He alleges that the court system's retention of the money judgment he won and its interference with his access to that award violated his rights under the Due Process and Takings Clauses of the United States Constitution, and under District of Columbia law governing theft, conversion, and unclaimed funds. Compl. ¶¶ 9-21, 35-44. Second, Croley claims that during the many years he sought to collect his money, administrative personnel in the D.C. court system violated federal disabilities law, including the ADA and Section 504 of the Rehabilitation Act.
Before the Joint Committee filed any responsive pleadings, the district court, on January 30, 2015,
sua sponte
dismissed Croley's complaint. In a one-page opinion, it stated that "plaintiff asks this Court to review the rulings of the District of Columbia courts," but that the court lacked jurisdiction to do so under the
Rooker
-
Feldman
doctrine.
Croley v. Joint Comm. on Judicial Admin.
,
II.
This appeal presents a single, threshold question: whether the
Rooker
-
Feldman
doctrine bars Croley's federal complaint.
Rooker
-
Feldman
's jurisdictional bar protects the Supreme Court's certiorari jurisdiction under Section 1257 of Title 28 of the United States Code. It ensures that the United States Supreme Court is the only federal court to hear appeals from judgments rendered by the highest court of a state (or, as here, the District of Columbia).
See
D.C. Court of Appeals v. Feldman
,
We review
de novo
the district court's dismissal of Croley's complaint on
Rooker
-
Feldman
grounds.
See
Whole Foods
,
We reject the Joint Committee's theory and reverse and remand to the district court because
Rooker
-
Feldman
does not bar Croley's claims: (i) He was a state-court winner, not a loser. (ii) The harms of which the current suit complains flow, not from any District of Columbia court judgment, but from administrative handling of money the RNC paid to the court in final satisfaction of a judgment. (iii) Croley's case seeks review and rejection not of any state-court judgment, but of the adequacy under property and disability law of court administrators' handling of funds entrusted
to them on Croley's behalf after the state court entered its judgment.
See
Exxon Mobil Corp.
,
A.
Croley first alleges that the Joint Committee violated his property rights by retaining and failing to distribute to him the money judgment he won and the RNC paid to the court registry. The court deemed the RNC's tort judgment satisfied, it paid out a portion of Croley's winnings to counsel to cover his fee, but then retained the balance of the funds for more than thirteen years. No District of Columbia court order required court administrators to withhold Croley's money from him, and no such order is on appeal here.
Croley rests his property claims on both D.C. law and the United States Constitution. He brings common-law claims for conversion and theft, Compl. ¶ 43, as well as for violation of the D.C. unclaimed funds law,
The
Rooker
-
Feldman
doctrine bars review only of judicial orders,
see
Feldman
,
Croley's property claims arise out of allegations of false and misleading conduct by the Clerk's Office or other administrative staff: "DC Courts persistently [misled] plaintiff Croley and various attorneys as to the location and status of plaintiff Croley's property," including when "DC Courts falsely advised [they] had conveyed plaintiff Croley's property to the 'US Treasury' without further specification." Compl. ¶ 19(d); see id. ¶ 37. Croley plausibly alleges that he contacted court administrators several times after the Court of Appeals affirmed the tort award in his favor and the court registry accepted payment in his behalf. See id. ¶ 19(d). As described above, each time Croley attempted to collect the money, the registry retained it and, each time, the disbursement process failed him. It is the actions of administrators, outside and independent of D.C. judicial proceedings, that Croley alleges frustrated collection of that judgment. Those actions do not implicate Rooker - Feldman 's bar.
The Joint Committee's assertion that Croley seeks reversal of the Superior Court's 2008 order denying his request for disbursement is unconvincing. The 2008 order, which stated that the $1.2 million was lost to court records, could indeed be appealed only to the D.C. Court of Appeals or ultimately to the Supreme Court. Croley's complaint, though, invokes that order only by way of background.
See
Compl. ¶ 18. The complaint does not seek to appeal the order itself-in fact, the Superior Court's 2015 disbursement order has already superseded the 2008 order denying payment, and Croley by no means asks to collect his judgment anew from the RNC. To the contrary, Croley here raises independent claims about administrators' conduct; those claims are not barred even to the extent that he seeks in the process to "den[y] a legal conclusion that a state court has reached in a case to which he was a party."
Exxon Mobil Corp.
,
Croley's property claims against the Joint Committee call for neither federal review nor reversal of any D.C. court order entered in his wholly distinct, closed tort case against the RNC. After all, Croley won in state court. That court entered final judgment in his favor. Croley's property claims against the Joint Committee allege different harms from the assault-based claims at issue in his suit against the RNC. They seek to enforce his legal rights against a different defendant, and seek a different remedy. Accordingly, lower federal court review of Croley's property claims is not an effort to appeal the D.C. court's judgment and is not barred by Rooker - Feldman .
B.
Croley's second set of claims alleges that, in his effort to gain possession of money paid to the court registry to satisfy his state court judgment, he was harmed by the D.C. court system's lack of the requisite policies and procedures for disability accommodation. He alleges, in particular, that the Joint Committee failed to meet its "affirmative obligation" under the ADA and the Rehabilitation Act "to accommodate persons with disabilities in the administration of justice" during the underlying litigation and, more importantly, award payment.
Tennessee v. Lane
,
These claims, too, are not barred by
Rooker
-
Feldman
. As the Supreme Court made clear in
Feldman
, lower federal courts may review a "general challenge" to an administrative rule or policy without impermissibly reviewing or reversing a particular state court judgment that assumed the policy was valid.
As discussed, Croley claims the Committee lacked requisite policies for responding to and assisting pro se litigants with cognitive or emotional disabilities. See, e.g. , Compl. ¶¶ 25-27. He alleges that "DC courts regard[ ] disability accommodation as a contested issue, to be repeatedly determined and re-determined as a matter of ongoing controversy throughout the course of each action before DC Courts." Id. ¶ 34(b); see id. ¶ 34(d). A court system in compliance with its affirmative federal obligations, Croley contends, would have as a matter of course afforded disabled litigants like him appropriate accommodations and would have published "clear, simple ... procedures" for navigating the court's requirements. Id. ¶ 30. Croley's complaint provides several "specific examples," id. ¶ 34, of administrative failures to meet those obligations, including court administrators' refusal to help him understand and access procedures for filing grievances against counsel and make various other complaints, see id. ¶¶ 34(c)(i)-(ii).
The Joint Committee artificially construes Croley's disability claims as limited to those specific examples and mischaracterizes Croley's claims as appeals of adverse rulings in an attempt to cast this case in
Rooker
-
Feldman
's mold.
See
Appellee's Br. 27-30; Oral Arg. Tr. 53:16-19;
see also
Compl. ¶ 34. The Committee invokes two rulings in particular: The Superior Court, as a sanction for Croley's failure to timely submit to a physical examination, prohibited Croley from introducing evidence of his brain injury,
see
As discussed above, however, Croley's complaint expressly makes a broader, general challenge to the District of Columbia courts' policies, Compl. ¶¶ 5, 30, 34(b), based on distinct harms it caused him: making it unduly hard for him, with his disabilities, to participate effectively in the litigation, and causing his property to be long withheld from him without clear means reasonably accessible to him for gaining possession of it. The Joint Committee recognized at argument that Croley's complaint "clearly" levies "general policy-like" challenges, independent of challenges to specific D.C. court orders.
See
Oral Arg. Tr. 54:4-11;
see also id.
at 51:10-54:11, 47:18-48:2. The different party he sues and the distinct damages he seeks confirm that federal review of his challenge to the court's disability policies would not disturb the state court's orders.
See
Gray
,
Whether those damages are available, and in what measure, turns largely on what the ADA guarantees to litigants in Croley's position. That question, however, speaks to the merits of Croley's claim
rather than to whether lower federal courts have jurisdiction to assess it. To be clear, to the extent Croley's complaint seeks damages based on counterfactual court victories Croley might have won against the RNC had the court not denied him enlarged time or limited his proof of brain injury,
Rooker
-
Feldman
is a bar. But Croley has pleaded a distinct federal claim challenging the Joint Committee's failure to afford ADA-compliant accommodation to disabled litigants. The ADA "authorizes private citizens to bring suits for money damages,"
Lane
,
III.
The Joint Committee maintains that, even were we to reverse the district court's Rooker - Feldman ruling, we should affirm its dismissal of Croley's complaint on non-jurisdictional grounds, such as judicial immunity, preclusion, or failure to state a legally cognizable claim including, for example, whether Croley would have a private right of action under the ADA's implementing regulations. We decline to reach those issues. We therefore reverse the district court's threshold jurisdictional dismissal and remand for the district court to consider the complaint anew. Motions to amend the complaint, or to dismiss it on grounds other than Rooker - Feldman , are for the district court to consider in the first instance on remand.
So ordered .
Reference
- Full Case Name
- John Douglas CROLEY, Appellant v. JOINT COMMITTEE ON JUDICIAL ADMINISTRATION, Appellee
- Cited By
- 7 cases
- Status
- Published