## Facts

- Jane Doe was admitted to the Florida bar in 2006 and practiced law in public and private settings.
- In 2014, Doe was diagnosed with bipolar I disorder and entered a monitoring program administered by the Florida Lawyer’s Assistance Program; she complied and remained in good standing.
- In 2015, Doe applied for admission to the Kentucky bar, an admissions process governed by the Kentucky Supreme Court and administered through the Character and Fitness Committee and the Board of Bar Examiners.
- As part of the application, Doe was required to disclose her diagnosis and sign releases allowing broad access to her medical records, including treatment notes.
- Doe’s treating physicians stated that she could practice law without concern, but the Character and Fitness Committee required Doe to sign a consent agreement for conditional admission shortly before she took the 2016 bar exam.
- Doe alleged she was told orally that Kentucky monitoring would mirror her Florida monitoring terms; she signed the consent agreement, passed the exam, and paid bar dues.
- At the swearing-in ceremony, a Kentucky Lawyer Assistance Program representative presented Doe with a standard monitoring contract that included conditions Doe viewed as unnecessary and stigmatizing, such as random drug testing, alcohol abstinence, and travel-notice requirements.
- Doe refused to sign the monitoring contract and asserted the conditions treated her “like a criminal” because of her disability.
- Over roughly two years, Doe engaged in negotiations and twice appeared at formal hearings where she was questioned about her disorder and related history.
- In 2018, Kentucky admitted Doe to practice law without conditions.
- Doe then sued the Supreme Court of Kentucky and bar-admissions entities and officials, alleging violations of Title II of the ADA, § 504 of the Rehabilitation Act, and the Equal Protection Clause, seeking damages and injunctive relief including removal of show-cause orders and medical records from her bar file.
- Defendants moved to dismiss; Doe sought leave to amend, and the court addressed dismissal after allowing the amended complaint to be filed.

## Issues

1. Whether the Eleventh Amendment barred Doe’s damages claims against the Kentucky Supreme Court and bar-admissions entities functioning as arms of the state in attorney-admission matters.
2. Whether absolute judicial or quasi-judicial immunity barred damages claims against individual officials for actions taken in the bar-admissions process.
3. Whether the Rooker–Feldman doctrine deprived the federal district court of jurisdiction to grant relief that would effectively review, nullify, or alter Kentucky bar-admission decisions or related orders and records.
4. Whether Doe had a live, redressable basis for prospective injunctive or declaratory relief after she had already been unconditionally admitted to the Kentucky bar, and whether any such claims fit within Ex parte Young.

## Decision

- The court granted Doe leave to amend and directed the clerk to file the amended complaint.
- The court granted defendants’ motions to dismiss and dismissed the action.
- Counts I–III were dismissed with prejudice.
- Counts IV–V were dismissed without prejudice.
- The court denied several other pending motions as moot (including Doe’s motion to proceed under a pseudonym).
- The court resolved the case on immunity and jurisdiction/justiciability grounds and did not reach the merits of whether the challenged admissions practices violated the ADA, the Rehabilitation Act, or equal protection.

## Legal Principles

- State courts and bar-admissions bodies acting as arms of the state are generally protected by Eleventh Amendment sovereign immunity from suits for damages in federal court absent waiver or valid congressional abrogation in the specific context at issue.
- Officials performing adjudicative functions in bar-admission proceedings may be shielded by absolute judicial or quasi-judicial immunity from damages for actions taken within that role.
- Under Rooker–Feldman, federal district courts lack subject-matter jurisdiction to provide relief that operates as appellate review of state-court judgments, including state supreme court decisions and orders connected to attorney admission.
- Ex parte Young permits certain suits for forward-looking relief against state officials to end an ongoing violation of federal law, but it does not authorize relief that is effectively retrospective or that would functionally revise past state-court actions.
- A plaintiff seeking injunctive or declaratory relief must show an ongoing or imminent injury that is redressable; once the challenged admission conditions have ended and admission has been granted, requests for forward-looking relief may be moot or too speculative.

## Conclusion

In Doe v. Supreme Court of Kentucky, the federal district court dismissed an attorney’s ADA, Rehabilitation Act, and equal-protection suit challenging Kentucky’s mental-health inquiries and conditional-admission monitoring in the bar-admissions process, holding that sovereign immunity, judicial/quasi-judicial immunity, Rooker–Feldman jurisdiction limits, and justiciability problems prevented the court from awarding damages or granting the requested injunctive relief after Doe’s unconditional admission.


Doe v. Supreme Court of Kentucky, 482 F. Supp. 3d 571 (2020)