Cladek v. Corrigan

CourtDistrict Court, District of Columbia
DecidedJuly 31, 2025
DocketCivil Action No. 2025-2066
StatusPublished

This text of Cladek v. Corrigan (Cladek v. Corrigan) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cladek v. Corrigan, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

LYDIA CLADEK,

Plaintiff,

v. Civil Action No. 25-2066 (TJK)

TIMOTHY J. CORRIGAN,

Defendant.

MEMORANDUM

Plaintiff, a prisoner proceeding pro se, sued a judge of the Middle District of Florida. She

alleges that at her sentencing, Judge Timothy J. Corrigan “violat[ed]” his “legal duty under 18

U.S.C. § 1519” by “falsifying the record of sentencing . . . thereby causing the government of the

United States . . . to cease to exist for the duration of Plaintiff’s sentencing proceeding . . . and

thereby causing the Constitution of the United States to cease to exist in every proceeding that

followed the sentencing proceeding.” ECF No. 1 at 3–4. She seeks punitive damages. Id. at 29.

Because any claims against Judge Corrigan are barred by absolute judicial immunity, the

Court will dismiss this action sua sponte. See Klayman v. Rao, No. 21-cv-2473 (CRC), 2021 WL

4948025, at *2 (D.D.C. Oct. 25, 2021) (dismissing case sua sponte on judicial immunity grounds).1

District courts “may sua sponte dismiss a claim” under Federal Rule of Civil Procedure

1 See also, e.g., Moore v. Burger, 655 F.2d 1265, 1266 (D.C. Cir. 1981) (affirming sua sponte dismissal of complaint against the justices of the Supreme Court); Jafari v. United States, 83 F. Supp. 3d 277, 278 (D.D.C. 2015) (dismissing sua sponte a claim against the judges of the Fourth Circuit under the Federal Tort Claims Act as barred by judicial immunity); Yi Tai Shao v. Roberts, No. 18-cv-1233 (RC), 2019 WL 249855, at *11 (D.D.C. Jan. 17, 2019), aff’d sub nom. Shao v. Roberts, No. 19-5014, 2019 WL 3955710 (D.C. Cir. July 31, 2019) (sua sponte dismissing claims for money damages against two California judges as barred by judicial immunity). 12(b)(6) “without notice where it is ‘patently obvious’ that the plaintiff cannot possibly prevail

based on the facts alleged in the complaint.” Rollins v. Wackenhut Servs., Inc., 703 F.3d 122, 127

(D.C. Cir. 2010) (citation omitted). That principle applies with full force here. “Judges enjoy

absolute judicial immunity from suits for money damages for all actions taken in the judge’s judi-

cial capacity, unless these actions are taken in the complete absence of all jurisdiction.” Martinez

v. Efman, No. 14-cv-1451, 2014 WL 6612151, at *1 (D.D.C. Nov. 18, 2014) (quoting Sindram v.

Suda, 986 F.2d 1459, 1460 (D.C. Cir. 1993)). Judicial immunity is absolute; it “extends even to

actions that are allegedly malicious or corrupt,” Sibley v. Roberts, 224 F. Supp. 3d 29, 37 (D.D.C.

2016), and “cannot be ‘overcome by allegations of bad faith or malice,’” Jafari v. United States,

83 F. Supp. 3d 277, 279 (D.D.C.), aff’d, 621 F. App’x 676 (D.C. Cir. 2015) (quoting Mireles v.

Waco, 502 U.S. 9, 11 (1991)). Here, Plaintiff’s lawsuit is “predicated on acts” Judge Corrigan

allegedly took “in [his] judicial capacity”—namely, at Plaintiff’s sentencing. Klayman, 2021 WL

4948025, at *3 (citation omitted); see ECF No. 1 at 3–4. So her claims are “barred by absolute

judicial immunity,” and she “fails to state a claim upon which relief may be granted.” Klayman,

2021 WL 4948025, at *4 (quoting Caldwell v. Kagan, 455 F. App’x 1 (D.C. Cir. 2011)). Simply

put, the remedy for any alleged mishandling of Plaintiff’s case is “an appeal,” not “a lawsuit

against” Judge Corrigan. Smith v. Scalia, 44 F. Supp. 3d 28, 42 (D.D.C. 2014) (internal quotation

marks omitted).

Accordingly, the Court will dismiss the case. A separate order will issue.

/s/ Timothy J. Kelly TIMOTHY J. KELLY United States District Judge

Date: July 31, 2025

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Related

Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
William Arthur Moore v. Warren Burger
655 F.2d 1265 (D.C. Circuit, 1981)
Sharon Rollins v. Wackenhut Services, Inc.
703 F.3d 122 (D.C. Circuit, 2012)
Smith v. Scalia
44 F. Supp. 3d 28 (District of Columbia, 2014)
Sibley v. Roberts
224 F. Supp. 3d 29 (District of Columbia, 2016)
Jafari v. United States
83 F. Supp. 3d 277 (District of Columbia, 2015)
Caldwell v. Kagan
455 F. App'x 1 (D.C. Circuit, 2011)

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Cladek v. Corrigan, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cladek-v-corrigan-dcd-2025.