SUMMARY
On July 30, 2025, the United States Court of Appeals for the Eleventh Circuit vacated the district court’s dismissal of Marsha W. Mignott’s case against the State Bar of Georgia Foundation, Inc. and sent it back for further proceedings. The opinion concerns the district court’s subject-matter jurisdiction. It does not decide her discrimination allegations.
The case before the appeal
On April 23, 2023, Marsha W. Mignott filed a putative class action in the Northern District of Georgia alleging race discrimination under 42 U.S.C. § 1981, arising from the State Bar disciplinary process. These are allegations in her filed complaint, not judicial findings. On October 24, 2023, in a separate disciplinary decision, the Supreme Court of Georgia wrote: “We therefore impose no discipline and dismiss this matter.” On December 27, 2023, the district court dismissed the action without prejudice for lack of subject matter jurisdiction. That order was the subject of the appeal.
What the court wrote
Eleventh Circuit published opinion, July 30, 2025, page 2: “Because federal, not state, law governs the subject-matter jurisdiction of the district court, we vacate and remand for further proceedings.”
Page 6: “We VACATE and REMAND for further proceedings.”
The ruling returned the case to the district court. It did not decide whether the discrimination allegations would succeed. The mandate issued August 28, 2025 (district Doc. 36), and the judgment was entered September 2, 2025 (Doc. 38).
What it does not decide
The opinion is not a decision about ADA Title II coverage of the State Bar. The records I hold through October 19, 2026, show no court ruling deciding the State Bar’s Title II public entity status.
Source: Eleventh Circuit No. 24-10327, opinion of July 30, 2025, pages 2 and 6.
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