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Croley v. Joint Committee On Judicial Administration

United States Court of Appeals, District of Columbia Circuit

July 6, 2018

John Douglas Croley, Appellant
Joint Committee on Judicial Administration, Appellee

          Argued April 23, 2018

          Appeals from the United States District Court for the District of Columbia (No. 1:15-cv-00175)

          Adele 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.

          John Croley, pro se, was on the briefs for appellant.

          Adam 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.

         In 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.

         Croley 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.

         Croley, 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 opinion.


         In his 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.

         Croley 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.

         At this 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 ...

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