The Third Circuit Court of Appeals has affirmed the dismissal of a federal lawsuit challenging Virgin Islands attorney disciplinary proceedings, ruling that constitutional protections do not override established principles of judicial abstention and immunity.
In *Lynch v. Donnelly*, decided Jan. 15, 2026, the appeals court upheld a district court's decision to dismiss claims filed by Peter Lynch, a Florida resident licensed to practice law in the Virgin Islands. Lynch had sued Kathryn Anne Donnelly, the Virgin Islands Special Designated Disciplinary Counsel, and Tanisha Bailey-Roka, the Chief Disciplinary Counsel, in both their official and individual capacities.
The case stems from an ongoing investigation by the Virgin Islands Office of Disciplinary Counsel into Lynch's conduct. According to court documents, the ODC opened an investigation into Lynch for allegedly engaging in improper solicitation of clients in violation of the Virgin Islands Rules of Professional Conduct. Chief Disciplinary Counsel Bailey-Roka initiated the proceedings that prompted Lynch's federal lawsuit.
Lynch argued that the disciplinary proceedings violated his constitutional rights, though the specific constitutional claims are not detailed in the available portions of the Third Circuit's opinion. His lawsuit sought relief from what he characterized as improper disciplinary actions taken against him by the Virgin Islands bar authorities.
The U.S. District Court for the Virgin Islands, presided over by Judge Mark A. Kearney, initially dismissed Lynch's claims on two primary grounds. First, the district court determined that federal courts must abstain from interfering with the ongoing state disciplinary proceedings under the *Younger* abstention doctrine. Second, the court found that the defendants were entitled to quasi-judicial immunity from the lawsuit.
The *Younger* abstention doctrine, established by the Supreme Court in *Younger v. Harris* (1971), generally requires federal courts to refrain from interfering with ongoing state judicial proceedings when certain conditions are met. The doctrine reflects principles of federalism and comity, recognizing that state courts are capable of addressing federal constitutional issues that arise in state proceedings.
Quasi-judicial immunity protects certain government officials from civil lawsuits when they are performing functions that are judicial in nature. This immunity extends to prosecutors, administrative law judges, and other officials who exercise discretionary judgment in quasi-judicial capacities. The immunity is designed to ensure that such officials can perform their duties without fear of personal liability for their official actions.
On appeal, Lynch challenged both grounds for dismissal. However, Circuit Judge Robert Porter, writing for a three-judge panel that also included Circuit Judges Thomas Hardiman and Stephanos Bibas, found no error in the district court's analysis.
The Third Circuit's opinion was issued as a non-precedential decision, meaning it does not establish binding precedent for future cases. The court noted that the disposition "is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent."
The case was submitted to the appeals court under Third Circuit Local Appellate Rule 34.1(a), which allows for disposition of certain appeals without oral argument when the issues are straightforward or when the parties agree to submit on the briefs.
The ruling represents a significant setback for Lynch's efforts to challenge the Virgin Islands disciplinary proceedings in federal court. With the federal avenue closed, Lynch will likely need to pursue any constitutional challenges through the state disciplinary process or state courts.
The decision also reinforces the broad protections afforded to bar disciplinary officials in the performance of their duties. Courts have generally been reluctant to allow federal interference with state bar disciplinary proceedings, viewing such matters as primarily within state jurisdiction.
Virgin Islands attorney discipline is governed by local rules that mirror many provisions of the Model Rules of Professional Conduct adopted by most U.S. jurisdictions. The territory's disciplinary system includes investigation procedures, formal charges, hearings, and appeals processes designed to ensure attorneys maintain professional standards.
The case highlights the tension between attorneys' rights to due process and constitutional protections, and the states' authority to regulate the legal profession within their borders. While attorneys retain constitutional rights during disciplinary proceedings, federal courts are generally reluctant to intervene in ongoing state proceedings absent extraordinary circumstances.
For practicing attorneys in the Virgin Islands and other jurisdictions, the decision serves as a reminder that challenges to disciplinary proceedings typically must be pursued through established state procedures rather than separate federal litigation. The ruling also demonstrates the substantial immunities that protect disciplinary officials from personal liability for their official actions.
The case record indicates that Lynch's underlying disciplinary matter remains pending before Virgin Islands authorities. The outcome of those proceedings will determine whether Lynch faces sanctions such as suspension, disbarment, or other disciplinary measures related to the alleged solicitation violations.