Joel L. Robinson v. Debra Stephens et al.

District Court, W.D. Washington·Decided April 2, 2026·No. 2:25-cv-02402·Unknown

Opinion

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3 4 5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 JOEL L. ROBINSON, CASE NO. 2:25-cv-02402-JNW 8 Plaintiff, ORDER 9 v. 10 DEBRA STEPHENS et al., 11 Defendants. 12 13 1. INTRODUCTION 14 This matter comes before the Court on ten pending motions. For the reasons 15 stated below, the Court GRANTS State Defendants’ motion to dismiss, Dkt. No. 20, 16 but DENIES all other motions, Dkt. Nos. 10, 23, 28, 30, 32, 33, 37, 38, and 51. 17 18 2. BACKGROUND 19 This is a section 1983 civil rights case. Plaintiff Joel Robinson sues five 20 Defendants, whom the Court separates into two groups—first, Washington 21 Supreme Court Chief Justice Debra Stephens and State Court Administrator Dawn 22 Marie Rubio (“State Defendants”); and second, King County, Superior Court 23 1 Presiding Judge Ketu Shah, and Department of Adult and Juvenile Detention 2 Director Allen Nance (“King County Defendants”).

3 Robinson describes himself as a “long-time licensed criminal paralegal who 4 operates J.R.’s Legal Services.” Dkt. No. 5 at 2. Robinson alleges that Defendants 5 violated his constitutional rights by applying “practice-of-law, courtroom, and 6 access-to-courts rules [against] him.” Id. at 3. Specifically, Robinson alleges that 7 King County Superior Court Judges Keenan, Donohue, and Thorp barred him from 8 “confidential access” to criminal defendants that he assists through the King

9 County Department of Public Defense’s (DPD) expert services policy. Id. at 13–15. 10 According to Robinson, DPD’s policy grants funds to indigent, pro se 11 defendants, which they can use to procure Robinson’s assistance. Id. at 9. Because 12 Judges Keenan, Donohue, and Thorp classified Robinson as an “unlicensed 13 practitioner,” Robinson cannot conduct confidential visits with incarcerated clients 14 or send privileged legal mail. Robinson alleges these restrictions preclude him from 15 “work[ing] as a paralegal” and claims Defendants are selectively targeting him as “a

16 Black man who primarily assists Black and low-income defendants” and a supporter 17 of the Republican party and Donald Trump. Id. at 12. 18 Robinson argues that, in treating him as “unlicensed,” Defendants violate his 19 First and Fourteenth Amendment rights to free speech, equal protection, and due 20 process. Id. at 15–18. Robinson seeks two injunctions: first, he seeks to enjoin 21 Defendants Stephens, Rubio, and Shah from interpreting case law and local rules to

22 “restric[t] his access to incarcerated clients on the ground that he is ‘unlicensed’”; 23 second, Robinson seeks to enjoin King County and Nance from “restricting his 1 access to incarcerated clients on the ground that he is ‘unlicensed’” and requests 2 private in-person visits to King County jail facilities, confidential “legal or expert

3 mail,” and privileged, unmonitored telephone communications. Id. at 19–20. 4 Robinson filed his original complaint on November 26, 2025. Dkt. No. 1. On 5 December 5, 2025, Robinson filed an amended complaint (First Amended Complaint 6 or FAC). Dkt. No. 5. The First Amended Complaint is the operative pleading. Fed. 7 R. Civ. P. 15(a)(1). 8 On January 13, 2026, Robinson filed a motion seeking leave to file a “[fourth]

9 amended complaint.” Dkt. No. 23 at 2. The Court believes this to be a scrivener’s 10 error and construes Robinson’s motion as seeking leave to file a Second Amended 11 Complaint (SAC). 12 3. DISCUSSION 13 3.1 State Defendants’ motion to dismiss, Dkt. No. 20. 3.1.1 Legal standards. 14 State Defendants argue that the FAC should be dismissed for failure to state 15 a claim under Federal Rule of Civil Procedure 12(b)(6) and lack of subject-matter 16 jurisdiction under Federal Rule of Civil Procedure 12(b)(1). Dkt. No. 20. 17 The Court will grant a Rule 12(b)(6) motion if the complaint fails to allege 18 “enough facts to state a claim to relief that is plausible on its face.” Bell Atl. Corp. v. 19 Twombly, 550 U.S. 544, 570 (2007). “A claim has facial plausibility when the 20 plaintiff pleads factual content that allows the court to draw the reasonable 21 inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 22 556 U.S. 662, 678 (2009). When considering a motion to dismiss, the Court accepts 23 1 factual allegations pled in the complaint as true and construes them in the light 2 most favorable to the plaintiff. Lund v. Cowan, 5 F.4th 964, 968 (9th Cir. 2021).

3 Dismissal is improper “if there is ‘any set of facts consistent with the allegations in 4 the complaint’ that would entitle the plaintiff to relief.” Frame-Wilson v. 5 Amazon.com, Inc., 591 F. Supp. 3d 975, 982 (W.D. Wash. 2022) (quoting Twombly, 6 550 U.S. at 563). 7 A motion to dismiss under Rule 12(b)(1) challenges the court’s subject-matter 8 jurisdiction. Federal courts are courts of limited jurisdiction and are presumed to

9 lack jurisdiction until the plaintiff establishes otherwise. Kokkonen v. Guardian Life 10 Ins. Co. of Am., 511 U.S. 375, 377 (1994). “Article III standing is an essential 11 ingredient of subject matter jurisdiction.” Perry v. Newsom, 18 F.4th 622, 630 (9th 12 Cir. 2021) (quoting Whitaker v. Tesla Motors Inc., 985 F.3d 1173, 1178 (9th Cir. 13 2021)). When evaluating a facial challenge to jurisdiction, the court accepts the 14 factual allegations in the complaint as true. Thornhill Publ’g Co. v. Gen. Tel. Elec., 15 594 F.2d 730, 733 (9th Cir. 1979).

16 Under the Federal Rules of Civil Procedure, “[p]leadings must be construed 17 so as to do justice.” Fed. R. Civ. P. 8(e). Thus, a “document filed pro se is to be 18 liberally construed and a pro se complaint, however inartfully pleaded, must be held 19 to less stringent standards than formal pleadings drafted by lawyers.” Erickson v. 20 Pardus, 551 U.S. 89, 94 (2007) (citations omitted). Courts are not to “dismiss a pro 21 se complaint without leave to amend unless ‘it is absolutely clear that the

22 deficiencies of the complaint could not be cured by amendment.’” Rosati v. Igbinoso, 23 1 791 F.3d 1037, 1039 (9th Cir. 2015) (citing Akhtar v. Mesa, 698 F.3d 1202, 1212 (9th 2 Cir. 2012) (quoting Schucker v. Rockwood, 846 F.2d 1202, 1204 (9th Cir. 1988))).

3 3.1.2 The Eleventh Amendment bars Robinson’s claims against State Defendants. 4 State Defendants move to dismiss Robinson’s claims for two reasons; first, 5 they argue Robinson fails to state claims against them because he does not allege 6 that either Chief Justice Stephens or Rubio personally participated in constitutional 7 violations; and second, they argue Robinson’s claims are barred by the Eleventh 8 Amendment. The Court agrees on both counts. 9 The allegedly unconstitutional conduct Robinson describes—judges 10 preventing him from confidential or privileged access to criminal defendants—is 11 specific to three King County Superior Court judges. He does not mention Chief 12 Justice Stephens or Rubio in any of the background facts.

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