Jackson v. Office of the Mayor of the Dist. of Columbia
Opinion
In 2010, the District of Columbia Court of Appeals Committee on Admissions ("Committee") denied Clarence Jackson's application to sit for the D.C. Bar Examination ("Bar"). Since then, Jackson has challenged that decision and, in turn, the handling of his challenge. His case reached the federal district court in 2016. The district court dismissed his complaint based on three alternative doctrines: the Rooker-Feldman doctrine, the Younger abstention doctrine and the doctrine of res judicata . Because none of the three doctrines applies, we reverse.
I.
Clarence Jackson sat unsuccessfully for the Bar four times. In 2010, he applied to sit a fifth time. He failed to pay the required fees or to provide proof of law school graduation and the Committee denied his application.
Five years later, Jackson sued the Committee in the D.C. Superior Court ("State Complaint"). He alleged that the denial of his application violated the Fourteenth Amendment to the United States Constitution, constituted a breach of contract and resulted in the intentional infliction of emotional distress. On April 1, 2016, the Superior Court granted without explanation the Committee's motion to dismiss the State Complaint.
On or around April 5, 2016, Jackson submitted a petition to the D.C. Mayor's Office in an apparent attempt to seek review of the decision denying him a further opportunity to take the bar exam. The Mayor's Office denied his petition on the ground that he had already filed a lawsuit making the same claim. Jackson then petitioned for review in the D.C. Court of Appeals, but his petition was denied as untimely.
On April 7, 2016, Jackson asked the Superior Court to explain why it dismissed the State Complaint. The request remained pending for more than one year.
In the interim, Jackson filed the instant complaint ("Federal Complaint"). This time Jackson sued both the Committee and the Mayor's Office ("Defendants"). He alleged that the denial of his application and the rejection of his challenge to that denial violated the Sixth, Thirteenth and Fourteenth Amendments,
1
as well as the Americans with Disabilities Act of 1990,
In June 2017, the Committee asked the Superior Court to resolve Jackson's request that the court explain its decision to dismiss the State Complaint. In July 2017, the Superior Court stated that it had not ruled on the request over the previous fifteen months because it believed its earlier decision was "a final adjudication" and that "the matter was closed." It clarified that it had dismissed the State Complaint "for many reasons," including its "lack[ ] [of] subject-matter jurisdiction over this action."
See
Kennedy v. Educ. Testing Serv., Inc.
,
Jackson timely appealed the district court's dismissal of the Federal Complaint. We review each alternative ground of the district court's decision
de novo
.
See
Croley v. Joint Comm. on Judicial Admin.
,
II.
The Defendants have all but abandoned their attempt to defend the district court's reliance on the
Rooker-Feldman
and
Younger
abstention doctrines and for good reason. The
Rooker-Feldman
doctrine prevents a federal district court from hearing "cases brought by state-court losers complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments."
Exxon Mobil Corp. v. Saudi Basic Indus. Corp.
,
Nor does D.C.'s doctrine of
res judicata
apply. The full faith and credit statute dictates that D.C. law governs this issue.
See
The Defendants acknowledge that the State Complaint was not dismissed "on the merits" but argue that
res judicata
nevertheless applies. They claim that
res judicata
applies if a party seeks to relitigate the same jurisdictional issue that led to an earlier dismissal, notwithstanding a jurisdictional dismissal is not rendered "on the merits." The Defendants are incorrect. Without exception, an earlier judgment must have been rendered "on the merits" for
res judicata
to apply.
Washington Med. Ctr.,
A dismissal for lack of jurisdiction
does
"preclude relitigation of the precise issue of jurisdiction that led to the initial dismissal."
GAF Corp v. United States
,
For the foregoing reasons, the judgment of the district court is reversed. The case is remanded for further proceedings consistent with this opinion. The district court is free to consider,
inter alia
, the alternative bases for dismissal set forth in the Defendants' motion to dismiss.
See
District Court Docket, ECF No. 17, at 1 (defendants' unaddressed grounds include their legal incapacity; Committee's immunity
from suit; statute of limitations bar; Jackson's failure to comply with
So ordered .
Reading the
pro se
Federal Complaint "liberally,"
Richardson v. United States
,
Reference
- Full Case Name
- Clarence JACKSON, Appellant v. OFFICE OF THE MAYOR OF the DISTRICT OF COLUMBIA and District of Columbia Court of Appeals Admissions Committee, Appellees
- Cited By
- 14 cases
- Status
- Published