CHICAGO (CN) – Federal courts lack jurisdiction to review the disbarment of a lawyer by the Illinois Supreme Court, the 7th Circuit ruled.
In 2008, the administrator of the Attorney Registration and Disciplinary Commission of the Supreme Court of Illinois filed a disciplinary complaint against Chicago-area attorney Mahendra Mehta.
Mehta, who was admitted to the bar in 1970, stood accused of misappropriating more than $100,000 in real estate escrow funds. The administrator said Mehta used those funds to pay sanctions ordered against him by bankruptcy court in Texas, and that he later falsely testified that his client had authorized him to take the funds.
While the disciplinary case was pending before the commission, the Illinois Supreme Court suspended Mehta’s license “effective immediately and until further order of the Court.”
Mehta challenged this suspension with a federal complaint, arguing that the Illinois Supreme Court’s action had created an “unconstitutional risk of bias” in the disciplinary proceedings.
A hearing board appointed by the commission later ruled that Mehta had broken four rules of professional conduct and recommended disbarment.
The Illinois Supreme Court disbarred Mehta on May 18, 2011, and U.S. District Judge Elaine Bucklo dismissed Mehta’s lawsuit five days later.
Bucklo concluded that the claims barred under the Rooker-Feldman doctrine, which precludes relitigation in federal court of state-court cases. The rule derives from two U.S. Supreme Court cases, Rooker v. Fidelity Trust Co. and District of Columbia Court of Appeals v. Feldman. Only the Supreme Court of the United States retains full authority to review state-court cases.
Five days before Bucklo’s order was entered,
The 7th Circuit affirmed Tuesday.
“Because the suspension order was the final judgment of a state court, we affirm the District Court’s judgment dismissing the suit under Rooker-Feldman,” the unsigned opinion states.