Trinh v. Fineman, No. 20-1727 (3d Cir. 2021)
Annotate this Case
Trinh sued Fineman, who had been appointed by the Court of Common Pleas of Philadelphia County as a receiver in a case involving the dissolution of Trinh’s beauty school. She alleged that Fineman did not give her a proper accounting of the escrow account related to that case and accused him of theft. The district court dismissed the complaint for lack of subject matter jurisdiction, explaining that Trinh had not raised “any claims arising under federal law or [alleged] that the parties are citizens of different states.” The Third Circuit remanded to allow Trinh to amend her complaint. Her amended complaint asserted that Fineman, as the receiver, was “abusing his state power.”
The Third Circuit affirmed the dismissal of the complaint. Although Trinh’s complaint arguably raised a section 1983 claim, Fineman, as a court-appointed receiver, is entitled to absolute, quasi-judicial immunity from suit when acting with the authority of the court. Erroneous, controversial, and even unfair decisions do not divest a judge of immunity. Fineman was duly appointed by the state court and the transcript of that court's hearing reflects that the judge was aware of, and approved of, all of his expenditures.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.