Michigan Lawyer Unable to Protest State Inquiry in Federal Court

Feb. 23, 2026, 3:19 PM UTC

A Michigan attorney is unable to challenge in federal court the propriety of an investigation into his conduct during litigation because regulation of lawyers’ conduct is a state interest, the US District Court for the Eastern District of Michigan said.

Marc Susselman is barred from pursuing a suit alleging that the Michigan Attorney Grievance Commission is violating his constitutional rights, Judge Shalina D. Kumar said in a Feb. 20 order granting a motion to dismiss.

Federal courts must avoid interfering in ongoing state proceedings absent extraordinary circumstances, which Susselman didn’t show, the order said. She dismissed the suit under the ...

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