Manchanda v. Attorney Grievance Committee 1st Department

Background

Rahul Dev Manchanda sought leave, or permission, to file another action challenging his disbarment from the New York bar. The opinion states that Manchanda was subject to a filing injunction in the Southern District of New York. That injunction required him to obtain permission before serving any document or motion and stated that violations could result in summary dismissal.

Although Manchanda acknowledged that the injunction applied in this District, he attempted to serve the defendants through counsel with a letter on May 15, 2025. He later filed a document titled “Proof of Service,” stating that he had served the Attorney Grievance Committee, First Judicial Department, and the New York Supreme Court, First Department. The court held that both actions violated the injunction.

Reasons for the Decision

The court identified several independent reasons for refusing to allow the action to proceed:

1. Violation of the filing injunction. The court held that Manchanda’s unauthorized service of documents violated the prior injunction and that these violations alone warranted summary dismissal.

2. No subject-matter jurisdiction under the Rooker-Feldman doctrine. Subject-matter jurisdiction is a court’s legal authority to hear a type of dispute. The Rooker-Feldman doctrine generally prevents federal district courts from functioning as appellate courts reviewing state-court judgments. The court concluded that, to the extent Manchanda sought review or reversal of the Attorney Grievance Committee’s decision and the state appellate court’s decision affirming his disbarment, the federal court lacked jurisdiction. The court said that presenting new legal theories in federal court did not avoid this rule because the action still complained of an injury caused by the state-court judgment and sought to have that judgment reversed.

3. No private right of action under the cited executive orders. A private right of action is a legal authorization for a private person to sue to enforce a law or directive. The court held that the five executive orders and related actions Manchanda cited did not create such a right. It noted that each order expressly stated that it did not create an enforceable right or benefit, and it found no indication that an executive order directed at federal executive-branch employees could be enforced against state employees serving on a state agency board.

4. Frivolous and repetitive filing. After reviewing the proposed complaint, the court characterized the lawsuit as another vexatious and frivolous filing. It said Manchanda was repeating grievances about his disbarment and again using offensive and pejorative terms concerning people he claimed had wronged him.

Disposition

The court declined to reopen the case or grant Manchanda leave to pursue the proposed action. It dismissed the action with prejudice, stated that the case was already closed and would remain closed, and called the order final.

The court also certified under 28 U.S.C. § 1915(a)(3) that any appeal would not be taken in good faith. As a result, it denied Manchanda permission to appeal without paying filing fees. The opinion does not decide whether the underlying disbarment was legally correct; its disposition rested on the filing injunction, lack of federal jurisdiction, the absence of a private right of action under the cited executive orders, and the nature of the proposed filing.