Judge Arthur Spatt
Asserting her medical license's unconstitutional revocation, Anghel asserted causes of action sounding in unreasonable search and seizure, abuse of process, First Amendment retaliation, frauds upon the court and under Federal Rule of Civil Procedure 9(b), and violations of due process and equal protection contrary to 42 USC §1983. Judgment was entered for defendants after the court found Anghel's claims barred by the Eleventh Amendment, facially invalid, or estopped. The court also found that her §1983 and state law conversion claims failed to state a cause of action. Permitting Anghel to file an amended motion for reconsideration, district court denied that motion. In addition to being barred by the Rooker-Feldman doctrine, Anghel's claims against the Health Department and senior state officials were barred by sovereign immunity and the Eleventh Amendment. As to her conversion claim the court noted that even if her medical license was "a specific identifiable thing" the United Defendants, as a private insurance company and one of its employees, had no authority to exercise dominion over it. Anghel acknowledged that the DOH's Bureau of Professional Medical Conduct rendered the decision to revoke her medical license.
