Jideani v. Rigsby

CourtDistrict Court, District of Columbia
DecidedNovember 9, 2023
DocketCivil Action No. 2023-3278
StatusPublished

This text of Jideani v. Rigsby (Jideani v. Rigsby) 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
Jideani v. Rigsby, (D.D.C. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

ONINYE JIDEANI, ) ) Plaintiff, ) v. ) Civil Action No. 23-3278 (UNA) ) ROBERT R. RIGSBY, ) ) Defendants. )

MEMORANDUM OPINION

This matter is before the Court on Plaintiff Oninye Jideani’s application to proceed in

forma pauperis, ECF No. 2, and pro se complaint, ECF No. 1. The Court will GRANT the

application and, for the reasons discussed below, DISMISS the complaint and this civil action

without prejudice.

According to the complaint, on May 9, 2022, Plaintiff filed a civil action against Hilton

Worldwide Holdings, Inc. in the Superior Court of the District of Columbia alleging violations of

the D.C. Human Rights Act. See Compl. at 6-8. Plaintiff alleges that the Clerk of Court

“unlawfully misclassified the May 09, 2022 Unlawful Discriminatory Practice suit . . . as one for

a Declaratory Judgment claim suit,” thereby “unlawfully denying its legal and jurisdictional

substantial merits.” Id. at 5 (emphasis omitted). Defendant, the judge to whom the case was

assigned, allegedly “deprived [Plaintiff] of [her] civil rights, privileges, and/or immunities

secured by the Constitution and laws” by “infring[ing] on [Plaintiff’s] substantive rights” and

“subject[ing her] to willful misconduct.” Compl. at 3. Plaintiff’s principal complaint is that

Defendant “dismissed the . . . action . . . during the first and only hearing held on October 21,

2022,” thereby allegedly “engag[ing] in unlawful and unjudicial conduct.” Id. at 5. As

1 compensation for Defendant’s having violated Plaintiff’s rights “in the capacity of his judicial

position at the District of Columbia Superior Court,” id. at 9, Plaintiff demands an award of $15

million under 42 U.S.C. § 1983, id., and that criminal charges be brought against Defendant

pursuant to 18 U.S.C. § 242, id.1

The Court cannot grant Plaintiff the relief she seeks for several reasons. First, Defendant

enjoys absolute judicial immunity. “Few doctrines were more solidly established at common law

than the immunity of judges from liability for damages for acts committed within their judicial

jurisdiction . . . .” Pierson v. Ray, 386 U.S. 547, 553–54 (1967). Here, even accepting the

complaint’s allegations as true, Defendant was acting in his judicial capacity when he issued, or

declined to issue, the rulings Plaintiff deems objectionable—indeed, Plaintiff states multiple

times that the alleged misconduct occurred “in the capacity of [Defendant’s] judicial position.”

Compl. at 3, 9. Absolute judicial immunity therefore protects him from suit. See Mireles v.

Waco, 502 U.S. 9, 11 (1991) (explaining that “judicial immunity is an immunity from suit, not

just from ultimate assessment of damages”); Stump v. Sparkman, 435 U.S. 349, 364 (1978)

(concluding that state judge was “immune from damages liability even if his [decision] was in

error”). To the extent Plaintiff seeks relief based on the action of other court officials, this

immunity extends to court staff who perform tasks integral to the judicial process. See Sindram

v. Suda, 986 F.2d 1459, 1460-61 (D.C. Cir. 1993) (per curiam); see also Roth v. King, 449 F.3d

1272, 1287 (D.C. Cir. 2006) (“It is well established that judicial immunity extends to other

officers of government whose duties are related to the judicial process.” (cleaned up)).

1 Plaintiff’s complaint also alleges misconduct or erroneous decisionmaking by the District of Columbia Court of Appeals during an appeal of Defendant’s decision, see Compl. at 5-6, though it does not name any of that court’s members as defendants. To the extent Plaintiff seeks to bring claims against the judges of the Court of Appeals, those claims would fail for the same reasons as the claims against Defendant. 2 Second, Plaintiff is no more successful in demanding that criminal charges be brought

against Defendant because there is no private right of action under 18 U.S.C. § 242, see, e.g.,

McCray v. Holder, 391 F. App’x 887 (D.C. Cir. 2010) (per curiam) (concluding that “district

court correctly held that there is no private right of action under 18 U.S.C. §§ 241 and 242”);

Rockefeller v. U.S. Ct. of Appeals Off., 248 F. Supp. 2d 17, 23 (D.D.C. 2003) (“[T]he plaintiff is

precluded from asserting any claims pursuant to 18 U.S.C. §§ 242 and 371 because, as criminal

statutes, they do not convey a private right of action.”), and Plaintiff cannot compel a criminal

prosecution, see United States v. Nixon, 418 U.S. 683, 693 (1974) (acknowledging that the

Executive Branch “has exclusive authority and absolute discretion to decide whether to prosecute

a case”); cf. Heckler v. Chaney, 470 U.S. 821, 831 (1985) (“[A]n agency’s decision not to

prosecute or enforce, whether through civil or criminal process, is a decision generally

committed to an agency’s absolute discretion.”).

Finally, to the extent Plaintiff asks this Court to review the underlying District of

Columbia court decisions to which she objects, her claims are barred by the Rooker-Feldman

doctrine. See, e.g., Singletary v. District of Columbia, 766 F.3d 66, 71 (D.C. Cir. 2014).

The Court will therefore dismiss Plaintiff’s complaint and this civil action without

prejudice. An appropriate Order will issue separately.

DATE: November 9, 2023 ANA C. REYES United States District Judge

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Related

Pierson v. Ray
386 U.S. 547 (Supreme Court, 1967)
United States v. Nixon
418 U.S. 683 (Supreme Court, 1974)
Stump v. Sparkman
435 U.S. 349 (Supreme Court, 1978)
Heckler v. Chaney
470 U.S. 821 (Supreme Court, 1985)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Roth, Pamela v. King, Rufus
449 F.3d 1272 (D.C. Circuit, 2006)
Singletary v. District of Columbia
766 F.3d 66 (D.C. Circuit, 2014)
McCray v. Holder
391 F. App'x 887 (D.C. Circuit, 2010)

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