Howard Herships, proceeding pro se, appealed a district court order that granted summary judgment and dismissed his case. Herships had filed a lawsuit under Title II of the Americans with Disabilities Act, the Rehabilitation Act of 1973, and 42 U.S.C. § 1983. His claims arose from proceedings in the Santa Clara County Superior Court, alleging discrimination due to his hearing impairment and other civil rights violations. The district court dismissed the case, and Hersips sought review in the Ninth Circuit.
The Ninth Circuit reviewed the case de novo. First, regarding the ADA and Rehabilitation Act claims, the court found that the district court correctly granted summary judgment because Hersips failed to raise a genuine dispute of material fact. Specifically, he did not provide sufficient evidence to show that the Superior Court discriminated against him because of his hearing impairment. Second, the court addressed the remaining claims against the Santa Clara County Superior Court. The appellate court determined these claims were barred by two distinct legal principles. The Rooker-Feldman doctrine prevents federal district courts from exercising jurisdiction over cases that seek to review or reject a state court judgment. Since Hersips was effectively asking the federal court to overturn the state court's actions, this doctrine applied. Additionally, the court noted that state courts are protected by Eleventh Amendment immunity, which shields them from suits in federal court. Finally, the court noted that Hersips failed to allege facts sufficient to state a plausible claim for the other defendants.
The decision affirms the dismissal of Hersips's federal lawsuit, leaving him without federal relief for his alleged civil rights violations stemming from state court proceedings. The ruling reinforces the strict application of the Rooker-Feldman doctrine, preventing federal courts from acting as appellate bodies for state court judgments. It also confirms that state courts enjoy Eleventh Amendment immunity in federal civil rights actions. The case is remanded to the district court with instructions to deny all pending motions, effectively ending the federal litigation.
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