Hurley v. Fuyat

CourtDistrict Court, D. New Hampshire
DecidedDecember 17, 1993
DocketCV-93-135-B
StatusPublished

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

Bluebook
Hurley v. Fuyat, (D.N.H. 1993).

Opinion

Hurley v. Fuyat CV-93-135-B 12/17/93 UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Peter H. Hurley

v. Civ. No. 93-135-B

John E. Fuyat, et al.

O R D E R

This action arises from the unsavory judicial conduct of

John E. Fuyat, a former Associate Justice of Rhode Island Family

Court. Plaintiff, a family court litigant, brought this civil

rights action pursuant to 42 U.S.C. §1983. Plaintiff alleged

that Fuyat's alcoholism, his persistent failure to perform his

judicial duties, and his solicitation and acceptance of "loans"

from opposing attorneys denied plaintiff his Fourteenth Amendment

right to procedural due process. Plaintiff sued Fuyat personally

and in his official capacity as an Associate Justice of Rhode

Island Family Court. He also named as defendants in their

official capacities three individuals whose ostensible duty it is

to ensure that Family Court judges do not deprive litigants of

their due process rights: Thomas F. Fay, the Chief Justice of

the Rhode Island Supreme Court; Jeremiah S. Jeremiah, the

Presiding Justice of the Family Court of the State of Rhode Island; and Thomas H. Needham, the Chairman of Rhode Island's

Commission on Judicial Tenure and Discipline. The claims

against Fuyat have been voluntarily dismissed. The remaining

defendants together now move that I dismiss the counts against

them pursuant to Federal Rule of Civil Procedure 12(b)(2) and

(6) .1

I. Facts

Plaintiff was the defendant in a divorce action assigned to

Judge Fuyat in 1988. Over the course of the litigation, Fuyat

allegedly solicited and accepted "loans" and "favors" from both

plaintiff's wife's attorney and the attorney representing

plaintiff's mother-in-law, an intervenor in the case. Plaintiff

contends that before trial, Fuyat solicited and accepted a $4,000

loan from the mother-in-law's attorney. Then, a few days after

the trial began, this attorney's law partner arranged for their

defendants have previously had their motion granted by Judge Boyle of the Federal District Court for the District of Rhode Island. Soon after issuing his opinion, however. Judge Boyle found out that his daughter had been offered a clerkship in Rhode Island Family Court for the upcoming term. To avoid any appearance of impropriety, the judge retracted his opinion and recused himself from the case. As the other judges from that district also have recused themselves for various reasons, the case has been assigned to me.

2 investment partnership to "loan" the judge a further $20,000.

Finally, in March 1989, when plaintiff had objections pending

before the court, Fuyat solicited a loan from plaintiff's wife's

attorney, who, as a "favor," arranged for a friend to "loan" the

judge $5 0,000.

Plaintiff further alleges that his divorce action was

plagued by unnecessary delays because Fuyat persistently failed

to perform his judicial duties. The action was first assigned to

Fuyat in June 1988 and the trial date set for September 23.

Fuyat's unexplained absences from the courtroom, however,

prompted six postponements. As a result, the trial did not begin

until November 30. Fuyat ultimately heard evidence on nine

separate occasions and concluded the case on May 4, 1989. During

this period, the proceedings were postponed at least ten times,

allegedly because Judge Fuyat was "absent or otherwise and

without explanation unavailable."2

2A s additional evidence of Fuyat's disregard for his judicial duties, plaintiff alleges that, rather than decide contested issues, Fuyat would retreat to chambers and endlessly urge attorneys to settle. Plaintiff contends that this style of case management, as well as the allegedly inordinate amount of time Fuyat spent attending to personal matters, resulted in backlogged cases, untimely decisions, and deferred and delayed proceedings.

3 Finally, plaintiff asserts that Fuyat's addiction to alcohol

and/or drugs contributed to the above delays and further tainted

the proceedings. To support this claim, plaintiff alleges that

Fuyat was an alcoholic throughout his tenure on the bench; that

Fuyat checked himself into an inpatient alcohol and drug

rehabilitation facility after the Chief Justice relieved him of

his duties on August 25, 1989;3 and that when Fuyat tendered his

resignation a month later, he cited alcoholism as the reason.

Plaintiff's complaint states that, although the other

defendants did not know of Fuyat's alcoholism or of the "loans"

until Fuyat's August 25 suspension, these defendants proximately

caused plaintiff's injuries. Plaintiff alleges that the Chief

Justice knew that drugs and alcohol were a national problem, yet

failed to establish the policies and procedures necessary to

ensure that the Rhode Island courts were drug and alcohol-free.

3Ihe Chief Justice of the Rhode Island Supreme Court was informed of Fuyat's creative financing technigues and promptly relieved him of his duties pending an investigation by the Commission on Judicial Tenure and Discipline. In September, the Presiding Justice informed plaintiff and the other parties to the divorce action that they had three options: (1) settle; (2) have another judge review the record and decide the case; or (3) relitigate. The parties decided to relitigate. On March 23, 1990, the Rhode Island Supreme Court disbarred Fuyat. Several months later, the Supreme Court also suspended the mother-in- law's attorney and his law partner.

4 Plaintiff also alleges that the Presiding Justice of the

Family Court knew or should have known of Fuyat's willful and/or

persistent failure to perform his judicial duties, but did not

refer him to the Commission on Judicial Tenure and Discipline.

While plaintiff primarily faults the Presiding Justice for this

failure, he also blames the Chief Justice and the Chairman of the

Commission. Plaintiff alleges that they failed to promulgate the

standards, policies and procedures necessary for supervisors like

the Presiding Justice to determine whether a subordinate judge

has willfully or persistently failed to perform his or her

judicial duties.

Plaintiff's complaint initially alleged 11 counts, seven

against Fuyat and four against the other defendants. By

stipulation, the counts against Fuyat have been either

"voluntarily dismissed" or "dismissed with prejudice". The

remaining counts -- Counts 3 through 6 -- are asserted solely

against the Chief Justice, the Presiding Justice and the Chairman

of the Commission.

Counts 3 and 4 seek to hold the three defendants liable for

failing to protect plaintiff from Fuyat's alcoholism and willful

failure to perform his judicial duties. Count 3 reguests that

the District Court declare that defendants, in their official

5 capacities, violated plaintiff's Fourteenth Amendment right to a

"meaningful hearing at a meaningful time" by failing to establish

policies and procedures to ensure that (1) "Rhode Island Family

Court is a drug and alcohol free workplace," and (2) that an

alcoholic or drug-addicted Family Court judge is promptly

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