Scheffler v. New Hope, City of

Background

Troy K. Scheffler, representing himself, filed claims arising from state-court proceedings on his petitions to expunge a 2010 speeding ticket issued by the City of New Hope. Minnesota State Court Judicial Referee Richard A. Trachy and Chief Judge Ivy S. Bernhardson denied his first petition. Minnesota Court of Appeals judges Francis J. Connolly, Lucinda E. Jesson, and James B. Florey later affirmed the order. Scheffler alleged that the judicial defendants misstated the expungement statute, made a finding that he was “factual[ly] guilty,” and denied him hearings, violating state and federal due-process rights.

A state court later granted Scheffler’s second expungement petition on January 2, 2019. The court therefore treated his requests for mandamus and declaratory relief concerning the denials of expungement as moot. Scheffler’s claims against the City of New Hope had already been dismissed under the parties’ stipulation, so the court did not analyze those claims and denied the city’s motion to dismiss as moot.

Issues and analysis

The judicial defendants moved to dismiss under Federal Rules of Civil Procedure 12(b)(1), for lack of subject-matter jurisdiction, and 12(b)(6), for failure to state a claim. The magistrate judge recommended dismissal based on absolute judicial immunity and, alternatively, the Rooker-Feldman doctrine, which generally prevents a federal district court from acting as an appeals court over state-court judgments. Scheffler objected, arguing that the defendants had acted outside their authority, maliciously, and in bad faith.

Judge Nelson conducted the required review of the objections and agreed that judicial immunity applied. The court explained that state judicial officers are immune from claims under 42 U.S.C. § 1983 when acting in their judicial capacity, unless they acted in the complete absence of jurisdiction. Issuing decisions in Scheffler’s expungement proceedings was part of the defendants’ normal judicial duties. The court rejected Scheffler’s argument that alleged legal errors, bad faith, or malice removed that immunity. It stated that such errors may be corrected on appeal, but do not justify litigation against the judges. The court also found that the pleadings did not establish that the defendants acted without jurisdiction and that repleading could not plausibly cure the problem without contradicting the existing pleadings.

The court separately adopted the Rooker-Feldman analysis in modified form. It held that claims arising from the first expungement proceeding were intertwined with the state-court decision because ruling for Scheffler would require finding that the state court’s decision was wrong. The doctrine therefore barred federal jurisdiction over those claims. The court held that Rooker-Feldman did not apply to claims arising from the second expungement proceeding because that proceeding was not complete when the federal case began. However, the court stated that abstention under Younger, a doctrine requiring federal courts in appropriate circumstances to refrain from interfering with ongoing state proceedings, would have been appropriate while the second proceeding was pending. The court did not decide the later preclusion-law analysis because it was beyond the scope of the magistrate judge’s recommendation. In any event, the court stated that judicial immunity applied to all of Scheffler’s claims.

Disposition

The court overruled Scheffler’s objections and adopted the magistrate judge’s February 15, 2019 Report and Recommendation as modified. It granted the Judicial Defendants’ motion to dismiss, denied the City of New Hope’s motion to dismiss as moot, and dismissed the matter with prejudice. The court directed that judgment be entered accordingly.