Reiner v. Guerrero

Background

Martin Reiner, representing himself, filed this case in August 2024. The opinion says he had repeatedly challenged California state-court orders declaring him a vexatious litigant and suspending or disbarring him from practicing law in California.

Reiner sued Patricia Guerrero, Jorge Navarrete, and several attorneys. He alleged that the defendants conspired and violated his constitutional rights by enforcing a California prefiling order and by relying on that order when seeking dismissal of an earlier case. Reiner claimed the state-court order was invalid, resulted from fraud, and was issued by a disqualified judge. He sought damages, punitive damages, and equitable relief, including discovery and a jury trial in connection with the earlier case.

Judicial Notice

The court granted the defendants’ requests for judicial notice. It took notice that the identified cases and documents were filed and of judicial findings contained in them.

Motions to Dismiss

The defendants moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which addresses subject-matter jurisdiction, and Rule 12(b)(6), which addresses whether a complaint states a legally sufficient claim.

The court held that the Rooker-Feldman doctrine barred any part of Reiner’s requested relief that sought to overturn the California vexatious-litigant order or the state-court dismissal of the earlier case. That doctrine prevents a federal district court from functioning as an appeal court for state-court judgments. The court distinguished any request for damages, which it said was not barred by that doctrine, but found that Reiner’s requests for declarations that the state orders were void were barred.

The court also held that collateral estoppel, also called issue preclusion, barred Reiner from relitigating whether the California vexatious-litigant order was void because of alleged fraud or a disqualified judge. The court found that Reiner had presented that argument in the earlier state-court case and that the state court had rejected it.

The court further ruled that Guerrero was protected by absolute judicial immunity and that Navarrete was protected by absolute quasi-judicial immunity. Those doctrines generally protect judges and certain court personnel from civil liability for acts performed as part of judicial proceedings. The court found that the claims against them were based on judicial or quasi-judicial acts.

Finally, the court held that the Noerr-Pennington doctrine barred Reiner’s claims against the attorney defendants. That doctrine generally protects people from liability for petitioning the government, including petitioning a court during litigation. The court rejected Reiner’s reliance on the doctrine’s exception for sham litigation because he did not plausibly allege intentional misrepresentations that deprived the earlier litigation of legitimacy.

The court granted the motions to dismiss. In its conclusion, it dismissed the case without leave to amend, finding that amendment would be futile.

Vexatious-Litigant Order

The defendants also asked the court to declare Reiner vexatious and require prefiling review of future complaints concerning specified subjects. The court applied the Ninth Circuit’s four-factor test, which requires notice and an opportunity to respond, an adequate record, substantive findings that the litigation was frivolous or harassing, and a narrowly tailored order.

The court found that Reiner received notice and an opportunity to oppose the motion and that the record showed he had filed nineteen cases, including this one, concerning the California disciplinary actions and vexatious-litigant order. After reviewing examples of those cases, the court found a repeated pattern of challenging the same orders, attributing adverse rulings to conspiracies or criminal conduct, and filing further lawsuits against people who disagreed with him. It found the litigation frivolous and harassing and granted the motion to declare Reiner vexatious in the Northern District of California.

The resulting order bars the Clerk from filing or accepting, without prefiling approval, any future complaint filed by or for Reiner that arises from or relates to the Workers’ Compensation Appeals Board sanctions order, his suspension or disbarment from practicing law in California, the California state-court vexatious-litigant order, or prior lawsuits concerning those matters. Reiner must submit the proposed complaint, a filing-request letter, and a copy of the order to the Clerk, who will forward them to the duty judge for a decision on whether the complaint may be filed. The order warns that violations may lead to contempt proceedings, sanctions, and dismissal.

Disposition

Judge Gilliam granted the motions to dismiss, dismissed the case without leave to amend, granted the motion to declare Reiner vexatious in the Northern District of California, directed entry of judgment for the defendants, and closed the case.