Appellant Tatiana Neroni, proceeding pro se, appeals the district court's order remanding her state disciplinary proceeding to New York State's Appellate Division based on lack of subject matter jurisdiction, and dismissing her 42 U.S.C. § 1983 claims based on the abstention principle announced in Younger v. Harris, 401 U.S. 37 (1971). We assume the parties' familiarity with the underlying facts, the procedural history of the case, and the issues on appeal.
"We review de novo a district court's decision on a motion to remand." Cuomo v. Crane Co., 771 F.3d 113, 115 (2d Cir. 2014). We also review de novo dismissals based on Younger abstention. Diamond "D" Constr. Corp. v. McGowan, 282 F.3d 191, 197 (2d Cir. 2002).
We affirm for substantially the reasons stated in the district court's thorough and well-reasoned November 18, 2013 opinion. See App'x at 6-10. In light of the Supreme Court's recent holding in Sprint Communications, Inc. v. Jacobs, 134 S.Ct. 584 (2013), however, we briefly revisit the issue of Younger abstention.
In determining that Younger abstention precluded consideration of Appellant's § 1983 claims, the district court applied a three-part test that this Court had previously derived from the Supreme Court's decision in Middlesex County Ethics Committee v. Garden State Bar Association, 457 U.S. 423 (1982). See Cecos Int'l, Inc. v. Jorling, 895 F.2d 66, 70 (2d Cir. 1990). After the district court's ruling, however, the Supreme Court rejected this three-part test in favor of a categorical approach. See Sprint, 134 S. Ct. at 591-94. It clarified that Younger abstention is triggered by only three categories of state court proceedings: (1) "state criminal prosecutions"; (2) "civil enforcement proceedings"; and (3) civil proceedings that "implicate a State's interest in enforcing the orders and judgments of its courts." Id. at 588, 591 (internal quotation marks omitted). State-initiated disciplinary proceedings against lawyers for violation of state ethics rules constitute "civil enforcement proceedings" implicating Younger. Id. at 592 (citing Middlesex, 457 U.S. at 433-34). Accordingly, the district court's conclusion that Appellant's claims were barred by Younger is still correct after Sprint.
We have considered all of Appellant's arguments and find them to be without merit. Accordingly, we