Jameel Ibrahim v. R. Hoffman

CourtCourt of Appeals for the Third Circuit
DecidedSeptember 18, 2025
Docket25-1973
StatusUnpublished

This text of Jameel Ibrahim v. R. Hoffman (Jameel Ibrahim v. R. Hoffman) 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
Jameel Ibrahim v. R. Hoffman, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT ___________

No. 25-1973 __________

JAMEEL IBRAHIM, Appellant

v.

JUDGE R. HOFFMAN, Personal Capacity ____________________________________

On Appeal from the United States District Court for the District of New Jersey (D.C. Civil Action No. 1:25-cv-03015) District Judge: Honorable Christine P. O’Hearn ____________________________________

Submitted Pursuant to Third Circuit LAR 34.1(a) August 27, 2025 Before: HARDIMAN, MATEY, and CHUNG, Circuit Judges

(Opinion filed September 18, 2025) ___________

OPINION* ___________

PER CURIAM

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. Jameel Ibrahim appeals pro se from the District Court’s order dismissing his

complaint pursuant to 28 U.S.C. § 1915(e)(2)(B). For the following reasons, we will

affirm the District Court’s judgment.

Ibrahim brought this action for “Civil Rights Violations” against R. Douglas

Hoffman, a former Springfield Township Municipal Court judge, in his individual

capacity.1 The complaint alleged that Hoffman violated Ibrahim’s due process rights and

the “Uniform Bonding Code” by compelling him to enter into a “surety contract” and,

thereby, undermining his ability to defend charges against him.2 Ibrahim sought both

monetary and injunctive relief. The District Court granted Ibrahim’s motion to proceed

in forma pauperis, and screened and dismissed the complaint with prejudice pursuant to

§ 1915(e)(2)(B), determining that Hoffman was entitled to judicial immunity. Ibrahim

timely appealed.

We have jurisdiction pursuant to 28 U.S.C. § 1291. We exercise de novo review

over dismissals under § 1915(e)(2)(B), see Allah v. Seiverling, 229 F.3d 220, 223 (3d

Cir. 2000), and over legal determinations regarding immunity, see Dotzel v. Ashbridge,

438 F.3d 320, 324-25 (3d Cir. 2006). To avoid dismissal for failure to state a claim, “a

1 We liberally construe Ibrahim’s pleading as a civil rights action pursuant to 42 U.S.C. § 1983. 2 Ibrahim attaches documents to his brief which suggest that his claims stem from proceedings in the Springfield Municipal Court related to various traffic violation charges against him. While “[w]e do not consider material on appeal that is outside of the district court record,” see Webb v. City of Phila., 562 F.3d 256, 261 n.4 (3d Cir. 2009), we note that the documents would not assist his appeal. 2 complaint must contain sufficient factual matter, accepted as true, to state a claim to relief

that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (citation and

internal quotation omitted). A plaintiff must offer more than conclusory allegations or a

simple recital of the elements of a claim. See Bell Atl. Corp. v. Twombly, 550 U.S. 544,

555 (2007).

We agree with the District Court that the claims against Hoffman are barred by the

doctrine of judicial immunity.3 Judges, including municipal court judges, are immune

from civil liability for acts taken in their judicial capacity. See Figueroa v. Blackburn,

208 F.3d 435, 440-41 (3d Cir. 2000) (recognizing that judicial immunity extends to

“judges of courts of limited and general jurisdiction”). “A judge will not be deprived of

immunity because the action he took was in error, was done maliciously, or was in excess

of his authority; rather, he will be subject to liability only when he has acted in the clear

absence of all jurisdiction.” Id. at 443 (citation omitted). Also, § 1983 bars injunctive

relief against “a judicial officer for an act or omission taken in such officer’s judicial

capacity . . . unless a declaratory decree was violated or declaratory relief was

unavailable.” Azubuko v. Royal, 443 F.3d 302, 304 (3d Cir. 2006) (per curiam) (quoting

42 U.S.C. § 1983).

3 In his complaint, Ibrahim also alleged claims against the Springfield Township Municipal Court. However, he did not name the Municipal Court as a defendant, and, in any event, he does not argue on appeal that the District Court erred in dismissing any such claims. See M.S. by & through Hall v. Susquehanna Twp. Sch. Dist., 969 F.3d 120, 124 n.2 (3d Cir. 2020) (noting that arguments not raised in an opening brief on appeal are forfeited). 3 Ibrahim argues that Hoffman “disregard[ed] the Uniform Bonding Code,” and that

his actions in “compel[ing] [him] to enter into a surety contract without due process,

clearly fall outside the protections of judicial immunity.” Appellant’s Br. at 2-3. As the

District Court observed, however, there is no legally cognizable “Uniform Bonding

Code.” Nor do the vague allegations regarding a “surety contract” clearly demonstrate

that Hoffman acted outside his judicial capacity or authority. Hoffman is therefore

entitled to immunity from this suit. See Azubuko, 443 F.3d at 304 (holding that

“[b]ecause [a plaintiff] has not alleged that a declaratory decree was violated or that

declaratory relief is unavailable, and because the injunctive relief sought by [the plaintiff]

does not address the actions of [the judge] other than in his judicial capacity, [the

plaintiff’s] claim for injunctive relief is barred”). Accordingly, the District Court

properly dismissed Ibrahim’s claims. Further, because amendment of the complaint

would be futile, dismissal of all claims with prejudice was appropriate. See Connelly v.

Steel Valley Sch. Dist., 706 F.3d 209, 217 (3d Cir. 2013).

Based on the foregoing, we will affirm the District Court’s judgment.

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Related

Bell Atlantic Corp. v. Twombly
550 U.S. 544 (Supreme Court, 2007)
Ashcroft v. Iqbal
556 U.S. 662 (Supreme Court, 2009)
Robert David Figueroa v. Audrey P. Blackburn
208 F.3d 435 (Third Circuit, 2000)
Connelly v. Steel Valley School District
706 F.3d 209 (Third Circuit, 2013)
Webb v. City of Philadelphia
562 F.3d 256 (Third Circuit, 2009)
Allah v. Seiverling
229 F.3d 220 (Third Circuit, 2000)
M. S. v. Susquehanna Twp Sch Dist
969 F.3d 120 (Third Circuit, 2020)

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