Case Explained: MAYNE V. FRAZER RYAN GOLDBERG & ARNOLD, LLP, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-08-04 Docket: 4:25-cv-00323-KAW The ninth-circuit affirmed the district court’s dismissal of Linda Furst Mayne’s complaint against her former attorneys. Although the court held that the Rooker-Feldman doctrine did not bar jurisdiction because Mayne alleged a legal injury caused by an adverse party rather than a state court judgment, it affirmed the dismissal on the alternative ground that the claims were time-barred. The court determined that the gravamen of the complaint was professional negligence (legal malpractice) arising from services rendered in July 2019, which is subject to Arizona’s two-year statute of limitations under Ariz. Rev. Stat. § 12-542. Because Mayne filed her complaint in January 2025, more than two years after the alleged wrongful acts, the claims were barred and amendment would be futile. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.