Natalia Sidiakina v. James Bertoli

MEMORANDUM

Natalia Sidiakina (Sidiakina) appeals the district court’s dismissal of her action under Title II of the Americans with Disabilities Act (ADA) against the Superior Court of' Sonoma County and related defendants. The district court dismissed Sidiakina’s entire complaint under the Roolcer-Feldman doctrine. Sidiakina appeals the dismissal of her claim that the California state courts’ policy of refusing to appoint counsel as an accommodation for qualified individuals with cognitive disabilities violated the ADA. Sidiakina concedes that the dis trict court properly dismissed a majority of her allegations under the Rooker-Feld-man doctrine. However, Sidiakina contends that the Rooker-Feldman doctrine does not preclude her prospective challenge to the state courts’ policy.

Even assuming the Rooker-Feldman doctrine does not preclude Sidiakina’s prospective challenge, we affirm the district court’s order of dismissal because Sidiaki-na lacks standing to bring this claim. Dismissal was proper because Sidiakina lacks standing to challenge the alleged policy against appointment of counsel. It is a well-established principle of law that a party seeking to demonstrate standing…