A Kansas attorney who was denied admission to join the Indiana bar can’t bring his suit against various state actors in federal court because of the Rooker-Feldman doctrine, the 7th Circuit Court of Appeals ruled Thursday.
Bryan K. Brown, who was a practicing attorney in Kansas before moving to Indiana, sought admission to practice here. The Indiana Board of Law Examiners referred Brown to the Judges and Lawyers Assistance Program for an evaluation. He was eventually denied admittance because he couldn’t demonstrate good moral character and fitness under Admission and Discipline Rule 12.
Brown appealed the decision to the Indiana Supreme Court, which left the BLE’s decision intact. The Supreme Court of the United States denied Brown’s petition for certiorari. He then brought a suit in federal court against JLAP, Indiana Chief Justice Randall T. Shepard and other state actors alleging federal and state constitution violations. Brown believed he was being prevented from joining the Indiana bar because of his religious beliefs.
Judge Theresa Springmann dismissed the suit, finding the claims were barred under the Rooker-Feldman doctrine because they were inextricably intertwined with the Indiana Supreme Court’s adjudication of his bar application and finding that his as-applied challenges to Admission and Discipline Rules were unripe. The 7th Circuit Court of Appeals agreed.
“Because Brown’s claims of religious bias require a federal district court to review the judicial process followed by the Indiana Supreme Court in deciding the merits of Brown’s bar admission application, Brown’s claims are ‘inextricably intertwined’ and fall squarely under Rooker-Feldman’s jurisdictional bar,” wrote Judge Richard Cudahy in Bryan J. Brown v. Elizabeth Bowman, et al., No. 11-2164. “Further, a simple reading of Brown’s complaint shows that his religious discrimination claims in district court are essentially the same arguments he made to the Indiana Supreme Court.”