Elijah White v. Jason Walsh

CourtCourt of Appeals for the Third Circuit
DecidedFebruary 19, 2026
Docket24-2981
StatusUnpublished

This text of Elijah White v. Jason Walsh (Elijah White v. Jason Walsh) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elijah White v. Jason Walsh, (3d Cir. 2026).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________

No. 24-2981 _____________

ELIJAH WHITE, Appellant

v.

JASON M. WALSH, Interim District Attorney of Washington County; JOHN F. DISALLE, in his Individual Capacity as President Judge of Washington County _____________

On Appeal from the District Court for the Western District of Pennsylvania (D.C. No. 2:23-cv-01883) District Judge: Honorable David S. Cercone _____________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) December 1, 2025 _____________

Before: CHAGARES, Chief Judge, FREEMAN and MASCOTT, Circuit Judges

(Filed: February 19, 2026)

____________

OPINION * ____________

* This disposition is not an opinion of the full Court and, pursuant to 3d Cir. I.O.P. 5.7, does not constitute binding precedent. CHAGARES, Chief Judge.

Elijah White was held in contempt of court following his invocation of his Fifth

Amendment right against self-incrimination when he was subpoenaed to testify as a

witness in a criminal proceeding. As a result, White filed suit against the judge that

presided over the contempt proceeding as well as against the prosecutor that filed the

contempt petition. The District Court dismissed the complaint, concluding that absolute

and judicial immunity barred White’s claims. We agree and will therefore affirm.

I.

We write primarily for the parties and recite only the facts essential to our

decision. On October 10, 2022, surveillance footage captured White speaking with

Jaison Irwin outside of a local bar; Irwin was murdered shortly after. The

Commonwealth eventually charged two individuals with Irwin’s murder. The prosecutor

handling the case, defendant-appellee Jason Walsh, subpoenaed White to testify at the

preliminary hearing. Once White took the stand, however, he invoked his Fifth

Amendment right against self-incrimination. The Magisterial District Judge presiding

over the hearing ultimately excused White.

Walsh, nevertheless, prepared a petition to hold White in contempt of court based

on his conduct at the preliminary hearing. At the time, the Washington County Court of

Common Pleas had an administrative order in place setting forth the assignment protocol

for the court (the “Administrative Order”). The Administrative Order assigned criminal

trials and motions primarily to two judges. Defendant-appellee Judge John DiSalle, in

contrast, was assigned to Problem-Solving Courts, Orphans’ Court, and administrative

2 duties.

Despite the Administrative Order, Walsh presented the contempt petition to Judge

DiSalle. Judge DiSalle then held a hearing on the petition and found White in contempt

of court. White was sentenced to a term of incarceration from five days to six months.

White was released after five days of incarceration. 1

White filed suit against Judge DiSalle and Walsh in the United States District

Court for the Western District of Pennsylvania, alleging that they violated his

constitutional rights and committed a variety of state-law torts. Judge DiSalle and Walsh

each moved to dismiss the complaint. The District Court granted the motions in full,

concluding that White’s claims against Judge DiSalle were barred by judicial immunity

and his claims against Walsh were barred by absolute immunity. White filed a timely

appeal thereafter.

II. 2

White challenges the District Court’s immunity determinations. As set forth

below, we see no error and will thus affirm the District Court’s order. 3

1 The Superior Court of Pennsylvania ultimately reversed the order. 2 The District Court had jurisdiction pursuant to 28 U.S.C. §§ 1331 and 1367. We have jurisdiction pursuant to 28 U.S.C. § 1291. We review the District Court’s decision to grant the motion to dismiss under a plenary standard. Connelly v. Lane Constr. Corp., 809 F.3d 780, 786 n.2 (3d Cir. 2016). 3 The District Court dismissed White’s state-law claims “for essentially the same reasons” as it dismissed the federal claims. Appendix 34 (concluding White’s state-law claims against the defendants are barred by absolute immunity, sovereign immunity, and high public official immunity). White does not advance any argument towards these claims specifically; we therefore will not address these claims separately.

3 We begin with the claims against Judge DiSalle. The District Court concluded

that these claims were barred by judicial immunity. We conduct a two-part inquiry to

decide whether judicial immunity applies. First, we consider whether the action is

nonjudicial, as a “judge is not immune from liability for nonjudicial actions.” Gallas v.

Sup. Ct. of Pa., 211 F.3d 760, 768 (3d Cir. 2000) (quoting Mireles v. Waco, 502 U.S. 9,

11 (1991)). Second, assuming the action is judicial, we ask whether the action was taken

“in the complete absence of all jurisdiction,” as those actions are similarly not entitled to

immunity. Id. (quoting Mireles, 502 U.S. at 12). We thus must distinguish between acts

taken in the “‘clear absence of all jurisdiction,’ which do not enjoy the protection of

absolute immunity, and acts that are merely in ‘excess of jurisdiction,’ which do enjoy

that protection.” Id. at 769.

White focuses his challenge on the second prong, contending that Judge DiSalle

acted in the clear absence of jurisdiction by presiding over White’s contempt proceeding

when the Administrative Order assigned that responsibility to other judges.

Nothing in the Administrative Order, however, alters the Pennsylvania legislature’s broad

grant of jurisdiction to the courts of common pleas. See 42 Pa. Cons. Stat. § 931(a);

Commonwealth v. Bethea, 828 A.2d 1066, 1074 (Pa. 2003). A procedural error such as

this one “at most might establish that [a judge] acted in excess of her jurisdiction, not that

she acted in the clear absence of all jurisdiction.” Gallas, 211 F.3d at 771; see also

Figueroa v. Blackburn, 208 F.3d 435, 444–45 (3d Cir. 2000). Thus, the District Court did

not err by applying judicial immunity to the claims against Judge DiSalle.

4 We next address the claims against Walsh. White challenges the District Court’s

application of absolute immunity to Walsh, urging that Walsh failed to overcome the

presumption that qualified immunity, rather than absolute immunity, applies. We have

held that in order to overcome this presumption, a prosecutor “must show that he or she

was functioning as the state’s advocate when performing the action(s) in question.” Odd

v. Malone, 538 F.3d 202, 208 (3d Cir. 2008). Immunity thus attaches to actions

“‘intimately associated with the judicial phases of litigation,’ but not to administrative or

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Related

Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Robert David Figueroa v. Audrey P. Blackburn
208 F.3d 435 (Third Circuit, 2000)
Odd v. Malone
538 F.3d 202 (Third Circuit, 2008)
Commonwealth v. Bethea
828 A.2d 1066 (Supreme Court of Pennsylvania, 2003)
Sandra Connelly v. Lane Construction Corp
809 F.3d 780 (Third Circuit, 2016)
Larry Roberts v. David Lau
90 F.4th 618 (Third Circuit, 2024)

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