Hurley v. Fuyat

District Court, D. New Hampshire·Decided December 17, 1993·No. CV-93-135-B·Published

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.

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.

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-inlaw 's attorney and his law partner.

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

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 "identified and rehabilitated and/or disciplined." Count 4 reguests that the District Court declare that defendants have violated plaintiff's Fourteenth Amendment rights by failing to establish policies and procedures to ensure that Family Court judges who willfully or persistently fail to perform their judicial duties are "promptly identified, disciplined and, if necessary, removed from office." In each count, plaintiff also seeks an injunction reguiring defendants to "establish and implement" the absent policies.

Free access — add to your briefcase to read the full text and ask questions with AI

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

Hurley v. Fuyat (Hurley v. Fuyat) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Conley v. Gibson
355 U.S. 41 (Supreme Court, 1957)
Flast v. Cohen
392 U.S. 83 (Supreme Court, 1968)
Haines v. Kerner
404 U.S. 519 (Supreme Court, 1972)
O'Shea v. Littleton
414 U.S. 488 (Supreme Court, 1974)
Schlesinger v. Reservists Committee to Stop the War
418 U.S. 208 (Supreme Court, 1974)
Rizzo v. Goode
423 U.S. 362 (Supreme Court, 1976)
Stump v. Sparkman
435 U.S. 349 (Supreme Court, 1978)
Quern v. Jordan
440 U.S. 332 (Supreme Court, 1979)
Parratt v. Taylor
451 U.S. 527 (Supreme Court, 1981)
City of Los Angeles v. Lyons
461 U.S. 95 (Supreme Court, 1983)
Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
Green v. Mansour
474 U.S. 64 (Supreme Court, 1986)
Daniels v. Williams
474 U.S. 327 (Supreme Court, 1986)