September 29, 2021

Judicial immunity and other bars to federal courts exercising jurisdiction over lawsuits challenging actions by a state court

The Plaintiff [Petitioner] appealed the dismissal of his pro se lawsuit in which New York State Unified Court System, its Office of Court Administration [OCA], and certain OCA personnel [collectively "Respondents"] were alleged to have violated Title II of the Americans with Disabilities Act of 1990 [ADA], 42 U.S.C. §§12131–12165, and §504 of the Rehabilitation Act, 29 U.S.C. §794 et seq. in the course of Plaintiff's family court action.

Petitioner alleged that Respondents denied certain of his requests for ADA accommodations and that he had suffered other damages in the course of his participation in certain New York State judicial and related proceedings.

1. With respect to Petitioner's claim for damages targeting a law clerk to a judge, the Circuit Court of Appeals concluded that judicial immunity bars such claims for damages. The court explained that “[A]cts arising out of, or related to, individual cases before the judge are considered judicial in nature” and protected by judicial immunity and "for purposes of absolute judicial immunity, judges and their law clerks are as one”. Accordingly, said the court, a law clerk "is sheltered from a damages claim for the actions taken by her in the capacity of court attorney."

 2. Addressing Petitioner's claims for injunctive and declaratory relief with respect to act or omissions of certain named Respondents, the Circuit Court of Appeals concluded all such claims against the Respondents must be dismissed in consideration of [a] the Rooker-Feldman doctrine, which prohibits federal courts from exercising jurisdiction over suits challenging final state court orders, and [b] the rulings in Younger [401 U.S. 37]  and O’Shea [414 U.S. 488] with respect to "abstention," which rulings caution that federal courts generally should refrain from enjoining pending state court proceedings. The Circuit Court of Appeals then opined that the federal district court "correctly concluded that it was either unlawful or imprudent for it to enter any order directing the state family court to conduct its affairs differently than it did in dealing with [Petitioner]." 

 3. With respect to claims for damages against OCA respondents, the Circuit Court of Appeals noted that although the district court "relied on the Eleventh Amendment in entering its dismissal order", it could affirm on any ground fairly presented by the record on appeal. It then so acted, "on the ground that [Petitioner] has failed to state a claim on which relief may be granted. The court explained that to establish a prima facie claim under either Title II of the ADA or §504 of the Rehabilitation Act, "a plaintiff must satisfy three requirements: he must show that (a) he is a “qualified individual” with a disability; (b) he was excluded from participation in a public entity’s services or programs or was otherwise discriminated against by a public entity; and (c) such exclusion or discrimination was due to his disability." Regardless of the correct resolution of claims advanced by Petitioner with respect to his being a "qualified individual" with a disability, the court concluded that Petitioner "has not plausibly alleged facts to satisfy the second and third requirements of the prima facie case."

4. As to Petitioner's assertion that OCA violated the ADA by failing to provide an ADA-compliant grievance procedure, the court noted that this assertion "is flatly contradicted" by both general information in the public record and specific records in Petitioner's case and the fact that "[t]he state court judicial record shows that [Petitioner] availed himself of these appeals processes." 

Accordingly, the court affirmed the district court’s dismissal of the damages claims against the Respondents as Petitioner "has not stated a claim on which relief may be granted."

Click HERE to access the Circuit Court of Appeals' decision.

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