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The Illinois Supreme Court will review a case pursuant to Ill. Sup. Ct. R. 708(e) only where there has been an arbitrary refusal to hear and consider evidence which may be presented, or if there was a manifest abuse of discretion. The court has clarified the point that the Committee on Character and Fitness's recommendation is advisory, and neither binds the Illinois Supreme Court nor limits its authority to take action.
Plaintiff Matthew Hale graduated from the Southern Illinois University School of Law and passed the Illinois bar exam. In his application for admission to the Illinois State Bar, he disclosed his active role in promoting racism and anti-Semitism. Hale’s application was denied. Pursuant to Ill. Sup. Ct. R. 708, Hale petitioned the Illinois Supreme Court to reconsider the Committee on Character and Fitness's denial. Hale asked the Illinois Supreme Court to review the constitutionality of the Committee's decision, in addition to challenging the constitutionality of the disciplinary rule against discrimination (Rule 8.4(a)(5) of the Illinois Rules of Professional Conduct). Hale's complaint squarely raised the claim that the Committee had violated the First and Fourteenth Amendments when it arbitrarily denied his bar application, because it based its decision not on any conduct in which Hale may have engaged, but instead solely on its speculation about his likely future conduct and its distaste for his political and religious beliefs. The Illinois Supreme Court denied Hale’s petition for review. Hale then filed a petition for a writ of certiorari with the Supreme Court of the United States, in which he presented his constitutional challenges to the Illinois Supreme Court's decision. The Supreme Court of the United States denied his petition without comment. Hale then filed an action before the federal district court, naming as defendants the Committee, the Board of Admissions to the Bar (Board), the Third District Committee, members of the Hearing Panel in their individual capacity, and the Illinois Supreme Court. The district court dismissed the entire lawsuit, holding that the Rooker-Feldman doctrine did not permit it to review the earlier decision of the Illinois Supreme Court. Hale appealed.
Under the circumstances, was there a “judicial proceeding” in the state supreme court which would preclude a lower federal court to take cognizance of the case?
The Court affirmed the judgment of the district court dismissing Hale’s action, holding that the fact that the court decided his appeals on a paper record did not mean that the court failed to decide the case on the merits. His challenge to the Illinois Supreme Court's decision not to admit him to the bar had been adjudicated, and he must take any further complaints he had about the outcome of that adjudication to the state courts of Illinois.