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Alia v. Michigan Supreme Court
Citations: 906 F.2d 1100; 1990 WL 83384Docket: No. 88-2095
Court: Court of Appeals for the Sixth Circuit; June 22, 1990; Federal Appellate Court
Plaintiffs filed a civil rights action against the Michigan Supreme Court, claiming it exceeded its authority in creating a mediation rule. The district court dismissed the case under Federal Rule of Civil Procedure 12(b), citing eleventh amendment immunity and qualified judicial immunity for the defendants. Additionally, the court imposed a $500 sanction on the plaintiffs' attorney for filing a "frivolous" complaint. Plaintiff Alia appeals both the dismissal and the sanctions, while the other plaintiffs chose not to appeal. The appellate court affirms the dismissal based on different reasoning but reverses the sanction due to dissenting opinions from Judges Wellford and Boggs. The federal action originated from two state lawsuits, one involving mediation in Wayne County and the other in Oakland County, both of which followed Michigan's mediation rules. The plaintiffs also previously pursued federal claims against the mediation panel, which were dismissed on the grounds of immunity. The plaintiffs sought damages and declaratory relief under 42 U.S.C. § 1983, alleging violations of equal protection rights due to the mediation rule. In Abick v. State of Michigan, 803 F.2d 874 (6th Cir.1986), the court upheld the dismissal of a claim against the justices of the Michigan Supreme Court regarding Michigan Court Rule 2.103 on service of process. The court asserted that the justices possess legislative immunity for actions related to the promulgation of court rules, which are classified as rules of practice and procedure. Article 6, Section 5 of the Michigan Constitution grants the Michigan Supreme Court authority to create such rules, and if a court rule conflicts with a statute, the rule prevails. Citing previous cases, the court noted that the Michigan Supreme Court's rule-making is a legislative function, similar to the findings in Supreme Court of Virginia v. Consumers Union of the United States, which established that justices acting in a rule-making capacity are entitled to legislative immunity. The ruling emphasized that this immunity applies to all forms of relief sought, including monetary damages or injunctive relief. The court referenced Mills v. Michigan Supreme Court, a previous case involving a challenge to a mediation rule brought by the same attorney, which was dismissed for similar reasons. The court clarified that while the Michigan Supreme Court enjoys immunity, this does not prevent challenges to the mediation rule, which should be addressed in a state forum rather than federal court. Parties dissatisfied with the mediation requirement can opt out, and any resulting dismissal can be appealed, allowing for a review of the rule's validity. The plaintiff contends that the district court incorrectly categorized the complaint as "frivolous," leading to a $500 sanction against the plaintiff's attorney. The plaintiff argues that the court failed to investigate whether the complaint had a factual basis or was supported by existing law. Sanction imposition under Rule 11 is evaluated based on an abuse of discretion standard. The district court judge was well-acquainted with the plaintiff's claims from both this case and a prior case involving the plaintiff's counsel. The review concluded that there was no abuse of discretion in imposing sanctions on the attorney, who was deemed the primary force behind the litigation, rather than the clients. The ruling was affirmed in part and reversed in part, noting that Alia’s claim might be moot due to his participation in mediation and acceptance of a settlement agreement.