United States District Court, M.D. Alabama, Northern Division
RECOMMENDATION OF THE MAGISTRATE JUDGE
CHARLES S. COODY UNITED STATES MAGISTRATE JUDGE.
an inmate incarcerated at the Elmore county Jail in Wetumpka,
Alabama, files this 42 U.S.C. § 1983 alleging that
rights, privileges, or immunities afforded him under the
Constitution or laws of the United States are being abridged
by the conduct and actions of Defendants. Specifically,
Plaintiff challenges the conditions of confinement at the
county jail and his continued incarceration despite the
charges on which his bond was revoked having been no billed.
Among the named defendants is Judge Sibley Reynolds. Upon
review, the court concludes that dismissal of Plaintiffs
claims against Defendant Reynolds prior to service of process
is appropriate under 28 U.S.C. § 1915(e)(2)(B).
Plaintiff was on bond for charges in Elmore County, Alabama,
but, following his arrest on new charges, his bond revoked.
The new charges were no billed, and Plaintiff complains Judge
Reynolds is violating his constitutional rights by denying
him bail. Plaintiff requests he either be released on bond or
that his bond be reinstated. Doc. 1. The allegations made by
Plaintiff against Judge Reynolds seek to challenge matters
which emanate from actions taken by him in his judicial
capacity during state court proceedings over which he had
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
Court, 150 Fed.Appx. 988, 990 (11th Cir. 2005)
(citing Roland v. Phillips, 19 F.3d 552, 555 (11th
Cir. 1994)). A state 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)).
court has reviewed Plaintiffs allegations against Judge
Reynolds and find they do not compel the conclusion that this
defendant acted in clear absence of jurisdiction.
Accordingly, Plaintiffs claims for monetary damages against
Judge Reynolds are “based on an indisputably meritless
legal theory” and are, 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).
Declaratory and/or Injunctive Relief
allegations against Judge Reynolds concern rulings and/or
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 Reynolds which are not yet final, he is not entitled
to relief from this court on such claims as 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.
respect to the claims presented by Plaintiff challenging the
constitutionality of orders issued by Judge Reynolds 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.' Exxon Mobil Corp. v. Saudi Basic
Industries Corp., 544 U.S. 280, 284, 125 S.Ct. 1517, 161
L.Ed.2d 454 (2005).” Lance v. Dennis, 546 U.S.
459, 460, 126 S.Ct. 1198, 1199 (2006). Although
“Rooker-Feldman is a narrow doctrine, ”
it remains applicable to bar Plaintiff from proceeding before
this court as this case, with respect to any claims
challenging final orders issued by a state court, is “
‘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.' 544 U.S.
at 284, 125 S.Ct. [at] 1517.” Lance, 546 U.S.
at 464, 125 S.Ct. at 1201; District of Columbia Court of
Appeals v. Feldman, 460 U.S. 462, 486 (1983) (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) (§ 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
light of the foregoing, the court concludes that dismissal of
the request for relief from final actions undertaken by Judge
Reynolds during proceedings related to Plaintiff's state
court criminal case is appropriate under 28 U.S.C. §
1915(e)(2)(B)(i). See Clark v. State of Georgia ...