Herbert Igbanugo v. Minnesota OLPR, No. 21-3826 (8th Cir. 2022)
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Plaintiff, an attorney, sued the Minnesota Office of Lawyers Professional Responsibility, the Minnesota Lawyers Professional Responsibility Board, associated government officials, and lawyers and other private defendants alleging, among other claims, they violated his constitutional rights by pursuing an ethics complaint against him. The district court granted the state defendants' motion to dismiss under Younger v. Harris and found that Plaintiff waived his abuse-of-process claim against the private defendants. The court also held that Plaintiff lacked standing to seek sanctions based on the private defendants' alleged violations of the Minnesota Rules of Professional Conduct.
Finding that the district court did not abuse its discretion in any of its determinations, the Eighth Circuit affirmed.
Court Description: [Gruender, Author, with Loken and Grasz, Circuit Judges] Civil case. Plaintiff, a lawyer, sued the Minnesota Office of Lawyers Professional Responsibility, the Minnesota Lawyers Professional Responsibility Board, associated government officials, and lawyers and other private defendants alleging, among other claims, they violated his constitutional rights by pursuing an ethics complaint against him; the district court did not abuse its discretion in abstaining from exercising jurisdiction against the state defendants under Younger v. Harris, 401 U.S. 37 (1971); plaintiff waived his abuse-of-process claim against the private defendants; plaintiff lacked standing to seek sanctions based on the private defendants' alleged violations of the Minnesota Rules of Professional Conduct; the district court did not abuse its discretion in assessing a $50,000 Rule 11 sanction against plaintiff as the claims in the suit were frivolous and motivated by retaliatory animus.
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