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Griffin v. March

2026-08-25

Summary

Holding. The district court dismissed the complaint based on the doctrine of res judicata, finding that the prior settlement agreement in D.C. Superior Court barred relitigation of the same claims. The court also found that claims concerning the attorney's alleged misconduct in the state court proceedings were barred by lack of federal jurisdiction under the Rooker-Feldman doctrine and that allegations of opposing counsel's ethical violations do not provide a private right of action in federal court. The complaint and motion for relief from judgment were dismissed, and the request for subpoenas was denied as moot.

Timothy Griffin, a Maryland resident, filed suit in federal district court against funeral home officials and an attorney for alleged mishandling of his deceased mother's funeral arrangements and for the attorney's alleged misconduct in prior litigation. The court granted Griffin's application to proceed without prepayment of filing fees but dismissed the entire case because Griffin had already litigated substantially identical claims in D.C. Superior Court. In that prior case, Griffin reached a settlement agreement in which he dismissed all similar claims with prejudice and agreed never to file additional litigation against the defendants or their corporate entities in any jurisdiction.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether res judicata bars federal litigation of claims previously settled and dismissed with prejudice in state court
  • Whether federal courts have jurisdiction to review allegations of attorney misconduct in state court proceedings under the Rooker-Feldman doctrine
  • Whether allegations of opposing counsel's ethical violations create a private right of action

Procedural posture

The plaintiff, proceeding pro se and in forma pauperis, filed a complaint in federal district court seeking damages; the defendant's application to proceed in forma pauperis was granted, but the case was dismissed on res judicata and jurisdictional grounds.

Authorities cited

Opinion

majority opinion

UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF COLUMBIA

)

TIMOTHY G. GRIFFIN, )

)

Plaintiff, )

)

v. ) Civil Action No. 1:26-cv-01670 (UNA)

)

VICTOR MARCH, SR., et al., )

)

Defendants. )

)

MEMORANDUM OPINION

This matter is before the court on Plaintiff’s pro se Complaint (“Compl.”), ECF No. 1, and

his Application for Leave to Proceed in forma pauperis (“IFP”), ECF No. 2. Upon review,

Plaintiff’s IFP Application is granted, and for the reasons explained below, this matter is dismissed.

Plaintiff, a resident of Maryland, sues three officials and an attorney associated with

Marshall-March Funeral Home, LLC, for damages. See Compl. at 1–2, 11–12. He alleges that

the Defendant officials committed myriad wrongs in caring for his deceased mother and

administering funeral arrangements, see id. at 4, 6, 8–10, that the Defendant attorney pursued

frivolous counterclaims against him in previous litigation, mishandled evidence in those

proceedings, and engaged in ex parte communications, see id. at 7, 9–10; Compl. Exhibits, ECF

No. 1-1; see also Griffin, Timothy G. v. Mar Corp Ltd., et al., No. 2021-CA-003993-B (D.C. Super.

Ct. filed Nov. 2, 2021) (“Griffin I”). Plaintiff has also filed a Motion for Relief from Judgment,

ECF No. 3, ostensibly related to those proceedings.

Plaintiff’s claims are barred by res judicata. “The doctrine of res judicata prevents

repetitious litigation involving the same causes of action or the same issues.” I.A.M. Nat'l Pension

Fund v. Indus. Gear Mfg. Co., 723 F.2d 944, 946 (D.C. Cir. 1983). And a court may dismiss a claim or issue sua sponte when it is on notice that that the claim or issue has been previously

decided, in an effort to prevent “unnecessary judicial waste.” Walker v. Seldman, 471 F. Supp. 2d

106, 114 n.12 (D.D.C. 2007) (quoting Arizona v. California, 530 U.S. 392, 412 (2000) (internal

quotation marks omitted)); see accord Rosendahl v. Nixon, 360 Fed. Appx. 167, 168 (D.C. Cir.

2010) (courts “may raise the res judicata preclusion defense sua sponte”) (citing Brown v. Dist. of

Columbia, 514 F.3d 1279, 1285–86 (D.C. Cir. 2008)) (other citation omitted). More specifically,

res judicata and collateral estoppel “are so integral to the administration of the courts that a court

may invoke [them] sua sponte[,]” Fenwick v. United States, 691 F. Supp. 2d 108, 116 (D.D.C.

2010) (alterations in original) (quoting McGee v. District of Columbia, 646 F. Supp. 2d 115, 123

(D.D.C. 2009); citing Stanton v. District of Columbia Court of Appeals, 127 F.3d 72, 77 (D.C. Cir.

1997)), because the Court bears a responsibility to “conserve judicial resources, avoid inconsistent

results, engender respect for judgments of predictable and certain effect, and to prevent serial

forum-shopping and piecemeal litigation[,]” Hardison v. Alexander, 655 F.2d 1281, 1288 (D.C.

Cir. 1981).

As discussed above, Plaintiff already filed a substantially similar lawsuit against March

Funeral Homes, LLC and Mar Corp, Limited in the Superior Court for the District of Columbia.

See generally Griffin I. Griffin I ultimately resulted in a settlement, in which Plaintiff agreed to

dismiss that matter, and two other substantially similar matters filed in D.C. Superior Court, all

with prejudice. See id. at Settlement Agreement Filed (Jan. 22, 2025). 1 Plaintiff also irrevocably

agreed “not to file any other litigation, appeal, petition, complaint or claim for damages against

Mar Corp, Limited, Marshall March Funeral Home LLC, Marshall-March Funeral Home of

1

A court may take judicial notice of the docket and facts on the public record in other court proceedings. See Covad Commc’ns Co. v. Bell Atl. Corp., 407 F.3d 1220, 1222 (D.C. Cir. 2005). Maryland, Inc., or any other March corporate entities or officers of those corporate March entities

in the District of Columbia, any state, or any federal jurisdiction.” See id. at 1. In exchange, the

Defendants dismissed their counterclaims against the Plaintiff. See id. at 2.

Whether a case is duplicative turns on whether the two cases at issue share the same

“nucleus of facts.” Drake v. Fed. Aviation Admin., 291 F.3d 59, 66 (D.C. Cir. 2002) (quoting Page

v. United States, 729 F. 2d 818, 820 (D.C. Cir. 1984)). And a final judgment on the merits of an

action precludes the parties or their privies from relitigating claims that “were or could have been

raised in that action.” Drake, 291 F.3d at 66 (emphasis in original) (quoting Allen v. McCurry, 449

U.S. 90, 94 (1980)); see also Apotex, Inc. v. Food & Drug Admin., 393 F.3d 210, 218 (D.C. Cir.

2004). Upon review, Griffin I unquestionably arises from the very same facts raised in the

Complaint filed in this matter, and the final adjudication of that matter thus bears preclusive effect

on this matter. See Franklin-Mason v. Mabus, 742 F.3d 1051, 1054 (D.C. Cir. 2014) (“We

summarily affirm the district court's dismissal of the employment discrimination claims. [A] suit

that has been dismissed with prejudice cannot be refiled; the refiling is blocked by the doctrine of

res judicata . . . Here, “[e]xecution of th[e] [Settlement Agreement] ... constitute[d] a dismissal

with prejudice.”) (citations and internal quotation marks omitted), aff’d, 692 Fed. Appx. 633 (Fed.

Cir. 2017), cert. denied, 584 U.S. 963 (2018).

Insofar as Plaintiff questions the actions of the attorney who represented the Defendant

in Murphy I, and seeks relief from the judgment entered in that matter, he must file for relief in

that case. Federal district courts generally lack jurisdiction to review or interfere with judicial

decisions made by state and local courts, see Fleming v. United States, 847 F. Supp. 170, 172

(D.D.C. 1994), (relying on District of Columbia Court of Appeals v. Feldman, 460 U.S. 462,

482 (1983)), and under the Rooker-Feldman doctrine, federal district courts may not hear “cases

that amount to the functional equivalent of an appeal from a state court.” Gray v. Poole, 275 F.3d

1113, 1119 (D.C. Cir. 2002). This prevents federal courts from considering issues, as here, that

are “so inextricably intertwined with a state court decision that the district court is in essence

being called upon to review the state-court decision.” Stanton v. D.C. Court of Appeals, 127 F.3d

72, 75 (D.C. Cir. 1997) (quotation marks and citation omitted). Federal jurisdiction is barred

even when the plaintiff claims “that the state judgment itself violates the [plaintiff’s] federal

rights.” Johnson v. De Grandy, 512 U.S. 997, 1005–1006 (1994). Additionally, allegations of

opposing counsel’s ethical misconduct do not generally confer a private right of action. See

Wagshal v. Rigler, 947 F. Supp. 10, 14 (D.D.C. 1996); In re Kinard, No. 17-1548, 2017 WL

11606023, at *1 (D.D.C. Aug. 18, 2017), appeal dismissed, No. 18-5039, 2018 WL 11301538

(D.C. Cir. Dec. 13, 2018), cert. denied, 589 U.S. 963 (2019); Matthews v. Pauze, No. 14–248,

2014 WL 667359, at *1 (D.D.C. Feb. 18, 2014).

For all of these reasons, the Complaint, ECF No. 1, and this case, are dismissed, 2 and

Plaintiff’s Motion for Relief from Judgment, ECF No. 3, is denied. Plaintiff’s Request for

Subpoenas to Issue, ECF No. 5, is denied as moot. A separate Order accompanies this

Memorandum Opinion.

__________/s/_____________

Date: August 25, 2026 AMIT P. MEHTA

United States District Judge

2

Plaintiff is forewarned that duplicative lawsuits filed by a plaintiff proceeding IFP are also subject to dismissal as either frivolous or malicious under 28 U.S.C. § 1915(e). See Sturdza v. United Arab Emirates, No. 09-0699, 2009 WL 1033269, at *1 n.2 (D.D.C. April 16, 2009), aff’d, 108 F.3d 1396 (D.C. Cir. Mar. 05, 1997); McWilliams v. State of Colo., 121 F.3d 573, 574 (10th Cir. 1997); Cato v. United States, 70 F.3d 1103, 1105 n.2 (9th Cir.1995); Pittman v. Moore, 980 F.2d 994, 994–95 (5th Cir.1993)).