## Facts

- J. Benedict Centifanti, a suspended Pennsylvania attorney, petitioned the Supreme Court of Pennsylvania for reinstatement and was denied.
- Pennsylvania’s attorney discipline and reinstatement process was governed by the Pennsylvania Rules of Disciplinary Enforcement, under which the Disciplinary Board makes recommendations and the Pennsylvania Supreme Court has final authority.
- After denial, Centifanti filed a federal action under 42 U.S.C. § 1983 against the Chief Justice and Associate Justices of the Supreme Court of Pennsylvania, in both individual and official capacities.
- The complaint alleged constitutional defects in the procedures and standards governing reinstatement petitions, asserting due process and equal protection violations.
- The relief sought was declaratory and prospective, directed at the rules and procedures governing future reinstatement consideration rather than reversal of the past denial.
- The district court dismissed for lack of subject matter jurisdiction under Rooker–Feldman and denied leave to amend; it also entered discovery rulings favoring the Justices based on privilege.

## Issues

1. Whether a § 1983 action seeking prospective declaratory relief against state court reinstatement procedures is barred as an impermissible de facto appeal under Rooker–Feldman.
2. Whether the district court abused its discretion by denying leave to amend the complaint under Federal Rule of Civil Procedure 15 to clarify the prospective, rules-based challenge.
3. Whether the action was barred by the statute of limitations or res judicata (claim preclusion).
4. Whether the district court abused its discretion in denying a motion to compel discovery and granting a protective order based on privilege.

## Decision

- The Third Circuit reversed the dismissal for lack of subject matter jurisdiction, holding the complaint (properly framed) asserted a permissible general constitutional challenge to state rules rather than review of a particular state judgment.
- The court reversed the denial of leave to amend, holding the district court abused its discretion because amendment would clarify and cure improper factual detail and Rule 15 favors liberal amendment.
- The court affirmed the district court’s discovery rulings, finding no abuse of discretion in denying the motion to compel and granting a protective order for privileged materials.
- The court held the suit was not barred by the statute of limitations or res judicata.
- The case was remanded for further proceedings on the merits of the constitutional challenge.

## Legal Principles

- Rooker–Feldman bars federal jurisdiction over claims that function as appellate review of final state-court judgments, but does not bar a forward-looking, general constitutional challenge to state rules or procedures.
- A plaintiff may seek prospective declaratory relief under § 1983 challenging the constitutionality of attorney discipline or reinstatement procedures without requesting reversal of a specific state-court decision.
- Leave to amend under Rule 15 should be freely granted when amendment can cure pleading or jurisdictional defects and does not unfairly prejudice defendants; denying such amendment may be an abuse of discretion.
- Statute of limitations and claim preclusion defenses do not necessarily apply where the federal claim targets allegedly unconstitutional rules and seeks prospective relief, rather than relitigating the validity of a prior adverse decision.
- Discovery management decisions, including protective orders for privileged internal judicial materials, are reviewed for abuse of discretion and may be upheld where privilege applies.

## Conclusion

The Third Circuit held that a § 1983 suit seeking prospective relief against Pennsylvania’s attorney reinstatement procedures was within federal subject matter jurisdiction because it challenged the rules generally rather than the prior reinstatement denial; it required the district court to permit amendment to clarify that posture, while leaving intact the district court’s privilege-based discovery protections and rejecting limitations and preclusion defenses.


Centifanti v. Nix, 865 F.2d 1422 (3d Cir. 1989)