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Chase v. Saufley

United States District Court, D. Maine

February 9, 2018

DANIEL L. CHASE, Plaintiff,
v.
LEIGH I. SAUFLEY, et al., Defendants

          RECOMMENDED DECISION ON DEFENDANTS' MOTION TO DISMISS

          John C. Nivison U.S. Magistrate Judge

         In this action, Plaintiff Daniel Chase alleges that Defendants[1] violated his constitutional rights and the Americans with Disabilities Act when the Supreme Judicial Court, sitting as the Law Court, affirmed the trial court's finding that Plaintiff committed a traffic infraction (operating a motor vehicle with an expired registration). (Complaint, ECF No. 1; Motion to Amend, ECF No. 33.)

         This matter is before the Court on Defendants' Motion to Dismiss. (ECF No. 21.) Through their motion, Defendants argue the Court is without subject matter jurisdiction to review the Law Court's decision, and that Plaintiff has failed to state an actionable claim for relief under the Civil Rights Act, 42 U.S.C. § 1983, or the Americans with Disabilities Act, 42 U.S.C. § 12132. Evidently in response to the motion to dismiss, Plaintiff filed a motion to amend his complaint, which motion the Court granted. (Order, ECF No. 47.)

         Following a review of the motion and the record, I recommend the Court grant Defendants' motion.

         Background Facts

          In the context of a motion to dismiss asserted under Federal Rule of Civil Procedure 12(b), it is appropriate for the court to review not only a plaintiff's allegations, but also facts “gleaned from documents incorporated by reference into the complaint, matters of public record, and facts susceptible to judicial notice.” Haley v. City of Boston, 657 F.3d 39, 46 (1st Cir. 2011). The facts in this case are derived from Plaintiff's complaint, Plaintiff's motion to amend, and the Law Court's opinion in the matter of State v. Chase, 2017 ME 43, 157 A.3d 1291.

         On April 29, 2016, after a bench trial, the Maine District Court entered judgment against Plaintiff on a charge that he failed to register a motor vehicle, in violation of 29-A M.R.S. § 351(1)(A). During the proceedings, the trial court denied Plaintiff's request for a jury trial, an interpreter or attorney who could explain the applicable rules of procedure, and/or a revised version of the applicable rules of procedure. The court, however, provided Plaintiff with transcription services to help him follow the proceedings. State v. Chase, 2017 ME 43, ¶¶ 2 - 4, 157 A.3d at 1291 - 92. At the trial, Plaintiff conceded that his motor vehicle was not registered; the court adjudicated the charge in favor of the state and imposed a fine. Id. ¶ 4.

         Plaintiff appealed from the District Court's judgment. On appeal, the Law Court rejected Plaintiff's contentions that he was entitled to a jury trial, to a revised version of the Maine Rules of Court, to the appointment of counsel, and/or to an interpreter to explain the Maine Rules of Court to him. Id. ¶¶ 5 - 6. In addition, the Court held that the accommodation provided by the District Court was sufficient under the circumstances. Id. ¶ 6 (“We also discern no error in the court's handling of Chase's various requests for accommodation for his claimed disabilities.”).

         In this case, Plaintiff contends that Defendants violated his constitutional rights and the Americans with Disabilities Act when they held that he was not entitled to a jury trial, the appointment of counsel, or any of the special accommodations he requested but did not receive. Id. ¶ 5. Plaintiff alleges that because of his learning disabilities, he finds the Maine Rules of Court to be “unreadable, ” and asserts that the transcription services provided by the trial court were not helpful. (Complaint at 3.)

         Discussion

         Defendants contend that this Court is without jurisdiction to review the Law Court's decision, and that Plaintiff has failed to allege facts that would support a claim for the violation of a federal right. (Motion to Dismiss at 1 - 2.)

         “Federal courts are courts of limited jurisdiction. They cannot act in the absence of subject matter jurisdiction, and they have a sua sponte duty to confirm the existence of jurisdiction in the face of apparent jurisdictional defects.” United States v. Univ. of Mass., Worcester, 812 F.3d 35, 44 (1st Cir. 2016). Pursuant to Federal Rule of Civil Procedure 12(b)(1), a defendant in a civil action may file a motion to dismiss based on the assertion that the court lacks jurisdiction to consider the subject matter of the plaintiff's action. When a defendant moves to dismiss an action on the ground that the court lacks jurisdiction over the subject matter, the plaintiff has the burden “to prove the existence of subject matter jurisdiction.” Aversa v. United States, 99 F.3d 1200, 1209 (1st Cir. 1996). If the court concludes it does not have subject matter jurisdiction, the court “must dismiss the action.” Fed.R.Civ.P. 12(h)(3).

         A. The Rooker-Feldman Doctrine

         Defendants argue that this Court is without jurisdiction based on the Rooker-Feldman doctrine.[2] Because the doctrine is jurisdictional, Defendants' argument arises under Rule 12(b)(1). Badill ...


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