District of Columbia Court of Appeals v. Feldman

Supreme Court of the United States · 1983 · Federal Courts

Federal Courtssubject-matter jurisdiction28 U.S.C. § 1257state-court reviewbar admissionjudicial proceedinggeneral constitutional challengeinextricably intertwined

Facts

The District of Columbia Court of Appeals had authority to regulate bar admissions and adopted Rule 461(b)(3), which required graduation from an approved law school. Feldman, who had not attended an approved law school, and Hickey, who graduated from an unapproved law school, each petitioned the D.C. Court of Appeals for a waiver so they could be admitted or sit for the bar exam. The D.C. Court of Appeals denied both petitions by per curiam orders after considering their individual qualifications and arguments. Each then sued in federal district court, alleging constitutional defects both in the denials of their own petitions and in the rule itself.

Issue

Whether the federal district court had subject-matter jurisdiction to review the District of Columbia Court of Appeals' denials of respondents' waiver petitions, and whether it could hear their constitutional challenges to the bar-admission rule itself. Also, whether the waiver proceedings before the D.C. Court of Appeals were judicial in nature.

Rule

Federal district courts have no authority to review final judgments of a state court, including the District of Columbia Court of Appeals, in judicial proceedings; review of those decisions lies only in the Supreme Court under 28 U.S.C. § 1257. However, federal district courts do have subject-matter jurisdiction over general challenges to state bar-admission rules promulgated by state courts in nonjudicial proceedings, so long as those challenges do not require review of a final state-court judgment in a particular case. A proceeding is judicial when the court is called on to investigate, declare, and enforce liabilities based on present or past facts under existing law, rather than to make rules for the future.

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Jordan Pike sought a waiver from the Oregon Supreme Court of a rule requiring graduation from an approved law school before taking the bar exam. After the court denied his waiver petition in a short order, Jordan sued in federal district court in Portland, alleging that the denial violated due process because the court failed to give adequate weight to his apprenticeship training and years of legal work.

Does the federal district court have subject-matter jurisdiction over Jordan's suit?

Explanation. When a state court considers an individual waiver request by applying existing law to the applicant's present qualifications and circumstances, the proceeding is judicial in nature. A federal district court may not review that final state-court judicial decision; review lies only in the U.S. Supreme Court. Framing the claim as a due process challenge to the denial does not create district-court jurisdiction.