Farina v. County of Napa, California

Background

Daniella Malmquist Farina filed a complaint without a lawyer against the County of Napa, California, and Judge Cynthia P. Smith. Farina voluntarily dismissed Judge Smith, leaving the County as the remaining defendant.

The dispute arose from a pending state-court partition action involving inherited property. Farina had asked Judge Smith for a reader to accommodate her visual disability. According to the complaint, state-court staff were available by appointment to read case documents for up to two hours each week. Farina alleged that the accommodation was inadequate because the readers were unqualified, reader services at hearings were absent or extremely limited, the readers were restricted to portions of documents directly related to her, and she was prevented from bringing a friend to read during a hearing.

Farina alleged violations of Title II of the Americans with Disabilities Act and the First and Fourteenth Amendments under 42 U.S.C. § 1983. She sought damages and injunctive relief.

Jurisdictional issue

The court independently examined whether it had subject-matter jurisdiction, meaning legal authority to hear the case. It focused on the Rooker-Feldman doctrine, which generally prevents a federal district court from acting as an appeal court reviewing an alleged legal error in a state-court decision or reviewing the state court’s procedures.

The court concluded that the claims appeared to challenge Judge Smith’s decision to provide only limited reader assistance and the way that decision was implemented. It said the state-court decision had finally resolved the reader-assistance issue that Farina sought to litigate again in federal court, even though the larger partition action remained pending in state court. The court also said Farina’s First- and Fourteenth-Amendment claims involved the same facts as the Americans with Disabilities Act claim and therefore appeared to be inseparably connected to it for purposes of the doctrine.

Ruling and present status

The court stated that Rooker-Feldman “thwarts all claims” and that it did not need to decide the merits of the Americans with Disabilities Act claim to conclude that Farina was bringing an impermissible federal appeal of a state-court order.

The court did not dismiss the remaining claims in this order. Instead, it ordered Farina to show cause within 21 days why the action against the County should not be dismissed for lack of subject-matter jurisdiction. The opinion does not state the result of any later response or dismissal.