District of Columbia Court of Appeals v. Feldman

Feldman (plaintiff) never enrolled in law school but worked in a Virginia law firm and audited law courses. Feldman passed the bar examination and was admitted to practice in Virginia. Feldman also practiced in Maryland, which waived its requirement of graduation from an ABA-accredited law school. Feldman sought the same waiver to practice in the District of Columbia, which denied the request. Feldman petitioned the District of Columbia Court of Appeals (defendant) for admission without examination or permission to sit for the examination. Feldman’s attorney wrote a letter to the court in support of Feldman’s petition based on Feldman’s alternative legal training, which was commensurate with law school, and the court’s plenary power to waive the law-school requirement in such circumstances. The letter also stated that Feldman was prepared to pursue constitutional and antitrust claims in federal district court. The District of Columbia Court of Appeals denied Feldman’s petition. Feldman filed a complaint in federal district court, seeking declaratory and injunctive relief. The district court dismissed the suit for lack of subject-matter jurisdiction. Feldman appealed. The United States Court of Appeals for the District of Columbia Circuit affirmed dismissal of Feldman’s antitrust claims and reversed and remanded on the constitutional claims, holding that Feldman’s petition for waiver to the District of Columbia Court of Appeals requested a policy decision and did not assert a legal right, so proceedings were not judicial and did not preclude litigation in federal court. The District of Columbia Court of Appeals appealed. The United States Supreme Court granted certiorari.