. . . Or Maybe the Principle Doesn’t Count After All
Thursday, May 31st by Robert LoblawRossi v. Gemma, 06-2020 (1st Cir., May 31, 2007)
Yesterday, in a post entitled “It’s the Principle That Counts,” I wrote about a Ninth Circuit appeal over a $25 processing fee. Judge Berzon’s lead opinion spoke proudly about redressing even the smallest of wrongs.
Apparently, the First Circuit does not share Judge Berzon’s enthusiasm for little cases. In this complicated decision involving lien laws, due process claims, the Rooker-Feldman doctrine, and Younger abstention, the Court reinstates the plaintiffs’ claims for money damages but urges them not to burden the federal courts further with their piddly litigation. Judge Lynch writes:
We make a further comment. The sum of money at issue in this lawsuit is surely not enough to have justified the extensive litigation in federal court. Plaintiffs initially chose to present their federal claims to the state courts, and they may wish to consider whether continuation of a stayed federal action is worthwhile.
Although it’s not clear from the decision how much the plaintiffs are seeking in damages, the plaintiffs’ claims center on a $36,000 lien on their home. Their damages are undoubtedly more substantial than the dozen or so Jamba Juices at stake in the Ninth’s decision. But perhaps principles aren’t so important to the First.
May 31st, 2007 at 3:27 pm
Besides the disparity in amounts, I think this case differs because it is a purely civil dispute. But there’s a certain haughtiness in the court inherent in the excerpt you printed, which suggests that its OK to bother state courts over piddling sums that don’t merit attention from a federal court. Then again, diversity jurisdiction is arguably, at least in part, based on precisely that notion!
By the way, your quantification of the amount in dispute by reference to the numberof Jamba Juices it would buy was hilarious and effective.
June 1st, 2007 at 7:16 am
CA1: Younger abstention in a lien fight…
Rossi et al v. Gemma et al., 06-2020 06-2021 (5/31/07). This case concludes that Younger abstention is warranted (see Younger v. Harris, 401 U.S. 37 (1971)). Anyway, what began as a lien enforcement proceeding (see Gem Plumbing Heating Co. v….