United States Court of Appeals, District of Columbia Circuit
April 23, 2018
Appeals from the United States District Court for the
District of Columbia (No. 1:15-cv-00175)
M. El-Khouri, appointed by the court, argued the cause as
amicus curiae in support of appellant. With her on the briefs
was Chad Golder.
Croley, pro se, was on the briefs for appellant.
Daniel, Assistant Attorney General, Office of the Attorney
General for the District of Columbia, argued the cause for
appellee. On the briefs were Karl A. Racine, Attorney
General, Loren L. AliKhan, Solicitor General, Stacy Anderson,
Acting Deputy Solicitor General, and Mary L. Wilson, Senior
Assistant Attorney General.
Before: Garland, Chief Judge, Pillard, Circuit Judge, and
Silberman, Senior Circuit Judge.
Pillard, Circuit Judge.
1985, John Croley brought a personal injury suit against the
Republican National Committee (RNC) in the District of
Columbia Superior Court after an RNC security guard
physically assaulted Croley while he was photographing an
overflowing dumpster near RNC headquarters. See Croley v.
Republican Nat'l Comm., 759 A.2d 682, 686 (D.C.
2000). A jury ruled in Croley's favor in 1998, awarding
him a $1.2 million judgment against the RNC. In 2002, the RNC
paid $1.37 million-that judgment plus interest-into the
District of Columbia court system's coffers. Croley's
lawyers promptly took their fee from that pot pursuant to an
attorney's charging lien against the sum. Croley himself,
however, did not then receive the remaining $1.25 million.
Croley did not get his money until 2015, thirteen years after
the RNC had paid in full.
here sues the Joint Committee on Judicial Administration, the
administrative arm of the D.C. court system, seeking
compensatory and punitive damages for what he alleges was the
Joint Committee's role in the events causing that
thirteen-year delay in receiving his payment. After the RNC
paid and counsel took their cut, Croley-suffering permanent
and disabling injuries from the assault-was left unable to
navigate the process of obtaining his money from the registry
at the Superior Court. The money the RNC paid to satisfy the
judgment was in the court's possession as of 2002 but,
Croley alleges, court administrators failed to release it to
him; they rebuffed his requests for assistance and for
reasonable accommodations for his disabilities, and they
misled him as to the funds' status. If the Joint
Committee had requisite disability accommodation policies in
place, Croley alleges, he would have had prompt possession of
his damages award. Instead, Croley was deprived for more than
a decade of funds meant to compensate him for, among other
things, his lost earnings. And he spent significant time,
expense, and energy over those many years in repeated,
unsuccessful efforts to dislodge his judgment from the
Superior Court-efforts that would have been entirely
unnecessary, he contends, if the Joint Committee had
fulfilled its legal obligations.
acting pro se, sued the Joint Committee in federal
court for damages. He claimed that the Joint Committee
violated his property rights and failed to comply with its
affirmative obligations under federal law to accommodate
disabled litigants. The district court sua sponte
dismissed Croley's complaint for want of federal
jurisdiction under the Rooker-Feldman doctrine. To
the extent Croley's complaint calls for appeal of a
District of Columbia court order issued in Croley's suit
against the RNC, any such claim is barred by
Rooker-Feldman. But Rooker-Feldman is no
bar to those portions of Croley's federal complaint
against the Joint Committee that do not seek to appeal orders
in his Superior Court suit against the RNC: Neither
Croley's claim that Superior Court administrative
personnel violated his property rights by misleading him and
mishandling his award, nor his claim that court
administrators neglected their legal duty to make the courts
accessible to persons with disabilities like his, necessarily
calls for the federal courts to review any state court
judgment. We therefore reverse the judgment of the district
court and remand for further proceedings consistent with this
1985 personal injury suit, Croley established that an
RNC-employed security guard attacked him, inflicting
post-traumatic stress disorder, chest trauma, and brain
injuries that left him permanently disabled. See
Croley, 759 A.2d at 686-88. Croley was photographing an
overflowing trash dumpster on the street where he lived,
planning to present the photos at an upcoming zoning meeting
as evidence of a public sanitation problem, when he was
approached by two security guards assigned to the RNC office
building on an adjacent property. Id. at 686. The
guards told Croley he was not permitted to engage in
nighttime activities on that street. Id. Croley,
believing he was acting within his rights on a public street,
kept taking pictures. Id. One of the guards then
assaulted and severely injured Croley. Id.
filed suit against the RNC and the security guard in D.C.
Superior Court. Following a seven-day trial in October 1998,
id. at 698, a jury awarded Croley $1.2 million,
id. at 689. In 2000, the D.C. Court of Appeals
affirmed. Id. at 694, 703.
threshold procedural stage, we have a limited record
chronicling the disconnect between Croley and the money the
RNC paid to satisfy his judgment. We rely on Croley's
pro se complaint, which we construe in the light
most favorable to him, see Brown v. Whole Foods Mkt.
Grp., 789 F.3d 146, 150 (D.C. Cir. 2015) (Whole
Foods), and also refer to the rather sparse and obscure
entries in the Superior Court docket in Croley's 1985
suit against the RNC, see Veg-Mix, Inc. v. Dep't of
Agric., 832 F.2d 601, 607 (D.C. Cir. 1987). Pro
se complaints like Croley's must be "liberally
construed" and "held to less stringent standards
than formal pleadings drafted by lawyers." Erickson
v. Pardus, 551 U.S. 89, 94 (2007) (quoting Estelle
v. Gamble, 429 U.S. 97, 106 (1976)); see alsoWhole Foods, 789 F.3d at 150, 152. We note that our
description of Croley's claims makes no determination ...