Family Law

Vena v. Moore, Schulman & Moore — Ninth Circuit Rejects Section 1983 Conspiracy Claims Against Law Firm Over Private Judge’s Undisclosed Relationships, but Concurrence Flags Growing Risks of Private Judging

/ May 11, 2026

The Ninth Circuit affirmed summary judgment for a law firm accused of conspiring with a private judge who failed to disclose multiple concurrent retentions, but a concurrence warned that private judging creates growing ethical risks that state courts should address.

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Vena v. Moore, Schulman & Moore — Ninth Circuit Rejects Section 1983 Conspiracy Claims Against Law Firm Over Private Judge’s Undisclosed Relationships, but Concurrence Flags Growing Risks of Private Judging