Roshan v. Lawrence, et al. – Do It For The Caselaw

Holding: The Ninth Circuit affirmed the district court's dismissal of the plaintiff's claims, ruling that the Rooker-Feldman doctrine barred challenges to state disciplinary proceedings and that the plaintiff lacked Article III standing for prospective relief.
Standard: Rooker-Feldman doctrine; Article III standing
Vote: The panel unanimously concluded the case was suitable for decision without oral argument.
Practical effect: The decision reinforces the Rooker-Feldman doctrine as a barrier to federal litigation challenging state attorney discipline outcomes and clarifies that speculative future disciplinary actions do not confer standing.

Roshan v. Lawrence, et al.

May 5, 2026 ·24-7429 ·Unpublished · By Aisha Johnson

The Ninth Circuit affirmed the dismissal of Peyman Roshan's federal claims against California State Bar officials. The court held that the Rooker-Feldman doctrine barred claims challenging state disciplinary proceedings and that Roshan lacked Article III standing for prospective relief.

Background

Peyman Roshan appealed a district court order dismissing his claims against Melanie Lawrence, George Cardona, and the Office of Chief Trial Counsel of the California State Bar. The district court had dismissed the case for lack of subject matter jurisdiction.

The court’s reasoning

The panel reviewed the dismissal de novo. The court held that the majority of Roshan’s claims were barred by the Rooker-Feldman doctrine because they constituted a de facto appeal of the Supreme Court of California’s denial of a petition for review. The court noted that an attorney’s as-applied claims challenging the State Bar’s discipline system fall under this bar. Regarding prospective relief, the court found Roshan lacked Article III standing because the suspension and revocation of his licenses were not redressable by judicial relief. The court also rejected his conjecture that the Office of Chief Trial Counsel might bring further disciplinary actions as insufficient to establish a likelihood of future injury.

What it means going forward

The decision reinforces the Rooker-Feldman doctrine as a barrier to federal litigation challenging state attorney discipline outcomes and clarifies that speculative future disciplinary actions do not confer standing.