PHILADELPHIA – A three-judge panel of the U.S. Court of Appeals for the Third Circuit has ruled that a trial court did not commit an error when it dismissed a tenant’s lawsuit against his landlord and other authorities for alleged constitutional rights violations.
Plaintiff Stanley Kornafel initially filed a complaint against his landlord, Dorothy Gallagher, his landlord’s attorney, Scott Galloway, and three Delaware County Court of Common Pleas judges, for alleged violations of his constitutional rights arising from a state court lawsuit that Gallagher successfully brought against him.
Kornafel alleged that the judges were biased against him, precluded him from presenting his case, and conspired against him with Galloway. Kornafel sought a “jury trial outside of Media where a reasonable fair and equal hearing may be had or adjudicate the case based on the merits.”
But, the District Court ruled that he did not allege the requisite race- or class-based discrimination to state a claim, that the District Court also ruled that Kornafel had not stated a conspiracy claim under Section 1983 because he did not allege facts supporting a plausible conspiracy, that his Section 1983 claims against the judges are barred by absolute judicial immunity, and that Gallagher and Galloway are not state actors subject to liability under Section 1983.
“The District Court dismissed the complaint without prejudice and allowed Kornafel to file an amended complaint, with the exception of his claims against the judges, which were dismissed with prejudice,” per the Third Circuit.
Kornafel then filed an amended complaint naming Galloway and the three judges as defendants, where he disputed the District Court’s decision and reiterated and expanded the allegations in his original complaint.
However, the District Court responded that the amended complaint made clear that Kornafel’s federal case was predicated on his dissatisfaction with the handling of his state court case and his belief that the judges and opposing counsel conspired against him.
The District Court ruled that, to the extent Kornafel asked it to review and vacate the state court’s judgment or rulings, it lacked jurisdiction to do so under the Rooker-Feldman1 doctrine. The District Court also ruled that Kornafel had failed to state a claim for the same reasons stated in its prior decision. The District Court dismissed the amended complaint with prejudice and the instant appeal followed.
A per curiam panel of the court then considered the appeal, comprised of Third Circuit judges Joseph A. Greenaway Jr., L. Felipe Restrepo and Julio M. Fuentes.
According to the Third Circuit, Kornafel’s complaints are “not very clear” and as to claims are not barred by the Rooker-Feldman doctrine, he “did not state a plausible conspiracy claim for the reasons stated by the District Court.”
The Third Circuit agreed that Kornafel’s allegations do not support a conclusion that Gallagher and Galloway are state actors subject to liability under Section 1983 and the judges are thus absolutely immune from any suit for damages.
“Kornafel argues on appeal that the District Court omitted from its decision certain factual allegations, including allegations that the state court failed to adjudicate his counterclaim against Gallagher and enforce its pre-trial order, and that these allegations support his conspiracy and due process claims,” the Third Circuit stated.
“Although the District Court summarized Kornafel’s complaints without setting forth all of his allegations of wrongdoing, Kornafel has not shown that the District Court erred in dismissing them for the reasons stated above. Accordingly, we will affirm the judgment of the District Court. Kornafel’s request in his brief for oral argument is denied.”
U.S. Court of Appeals for the Third Circuit case 18-2976
From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at nick.malfitano@therecordinc.com