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Ellison v. Autauga County Circuit Court

United States District Court, M.D. Alabama, Northern Division

September 4, 2018

VINCENT ELLISON, Plaintiff,
v.
AUTAUGA COUNTY CIRCUIT COURT, ALABAMA, et al., Defendants.

          RECOMMENDATION OF THE MAGISTRATE JUDGE

          GRAY. M. BORDEN, UNITED STATES MAGISTRATE JUDGE

         Plaintiff, an inmate incarcerated at the Autauga Metro Jail in Prattville, Alabama, files this 42 U.S.C. § 1983 action against the Autauga County Circuit Court, the Autauga County District Attorney's Office, District Attorney Randall Houston, and Judge Ben Fuller. He alleges that rights, privileges, or immunities afforded him under the Constitution or laws of the United States were being abridged by the conduct and actions of Defendants regarding his state criminal proceedings before the Circuit Court for Autauga County, Alabama. Plaintiff requests declaratory relief, injunctive relief, and damages. Upon review, the court concludes that dismissal of this case prior to service of process is appropriate under 28 U.S.C. § 1915(e)(2)(B).[1]

         I. DISCUSSION

         A. Judge Fuller

         1. Damages

         Plaintiff complains Judge Fuller entered orders prohibiting him from filing motions pro se and allowed his attorney to withdraw from his case after it had been set for trial without filing a written motion or stating reasons for the request to withdraw. Doc. 1. The allegations made by Plaintiff against Judge Fuller seek to challenge actions taken by him in his judicial capacity during state-court proceedings over which he had jurisdiction.

         “Judges have absolute immunity from civil actions for the performance of judicial acts as long as they are not done in the clear absence of jurisdiction.” See Jenkins v. Clerk of Ct., 150 Fed.Appx. 988, 990 (11th Cir. 2005) (citing Roland v. Phillips, 19 F.3d 552, 555 (11th Cir. 1994)). A circuit court judge is, thus, entitled to absolute immunity from damages for actions taken in his official capacity, even when his actions are allegedly erroneous, malicious, or in excess of his jurisdiction. Stump v. Sparkman, 435 U.S. 349 (1978); Wuyisa v. City of Miami Beach, 614 Fed.Appx. 389, 391 (11th Cir. 2015) (citing Bolin v. Story, 225 F.3d 1234, 1239 (11th Cir. 2000)).

         The court has reviewed Plaintiffs allegations against Judge Fuller and finds that they do not compel the conclusion that this defendant acted in clear absence of jurisdiction. Accordingly, Plaintiffs claim for monetary damages against Judge Fuller is “based on an indisputably meritless legal theory” and is, therefore, subject to dismissal under 28 U.S.C. § 1915(e)(2)(B)(i) and (iii). Neitzke v. Williams, 490 U.S. 319, 327 (1989).

         2. Declaratory and Injunctive Relief

         a. Non-Final Orders

         Plaintiffs allegations against Judge Fuller concern rulings and decisions he made in his judicial capacity during state-court criminal proceedings over which he had jurisdiction. To the extent Plaintiff seeks relief from adverse decisions issued by Judge Fuller which are not yet final, he is not entitled to relief from this court on these claims because there is an adequate remedy at law. Bolin, 225 F.3d at 1242 (“In order to receive declaratory or injunctive relief, plaintiff[] must establish that there was a [constitutional] violation, that there is a serious risk of continuing irreparable injury if the relief is not granted, and the absence of an adequate remedy at law.”). Specifically, Plaintiff could appeal orders issued by the state court to the appropriate higher state court. Since state law provides an adequate remedy for Plaintiff to challenge non-final orders, Plaintiff is “not entitled to declaratory or injunctive relief in this case.” Id. at 1243.

         b. Final Orders

         With respect to the claims presented by Plaintiff challenging the constitutionality of orders issued by Judge Fuller which have become final in accordance with state law, this court lacks jurisdiction to render such judgment in an action filed pursuant to 42 U.S.C. § 1983. “The Rooker-Feldman doctrine prevents . . . lower federal courts from exercising jurisdiction over cases brought by ‘state-court losers' challenging ‘state-court judgments rendered before the district court proceedings commenced.'” Lance v. Dennis, 546 U.S. 459, 460 (2006) (quoting Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280, 284 (2005)). Although “Rooker-Feldman is a narrow doctrine, ” it bars claims “brought by [a] state-court loser[] complaining of injuries caused by state-court judgments rendered before the district court proceedings commenced and inviting district court review and rejection of those judgments.” Lance, 546 U.S. at 464 (citation and quotation makrs omitted); D.C. Ct. of App. v. Feldman, 460 U.S. 462, 486 (1983) (holding that federal district courts “do not have jurisdiction . . . over challenges to state court decisions in particular cases arising out of judicial proceedings even if those challenges allege that the state court's action was unconstitutional”). Moreover, a § 1983 action is inappropriate either to compel or to appeal a particular course of action by a state court. Datz v. Kilgore, 51 F.3d 252, 254 (11th Cir. 1995) (holding that a § 1983 suit arising from alleged erroneous decisions of a state court is merely a prohibited appeal of the state court judgment); see also Rolleston v. Eldridge, 848 F.2d 163 (11th Cir. 1988).

         In light of the foregoing, the court concludes that dismissal of the request for relief from final actions undertaken by Judge Fuller during proceedings related to Plaintiff's state-court case is appropriate under 28 U.S.C. § 1915(e)(2)(B)(i). See Clark v. St. of Ga. Pardons ...


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