Jones v. King

CourtCourt of Appeals for the Fifth Circuit
DecidedAugust 1, 2025
Docket23-50850
StatusPublished

This text of Jones v. King (Jones v. King) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fifth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jones v. King, (5th Cir. 2025).

Opinion

Case: 23-50850 Document: 66-1 Page: 1 Date Filed: 08/01/2025

United States Court of Appeals for the Fifth Circuit ____________

No. 23-50850 ____________

Matthew Jones; Ysidro Renteria; William L. Jones Carr,

Plaintiffs—Appellees/Cross-Appellants,

versus

Amber M. King; Chris H. Busse; Brandon W. Jones,

Defendants—Appellants/Cross-Appellees. ______________________________

Appeal from the United States District Court for the Western District of Texas USDC No. 4:22-CV-30 ______________________________

Before Higginbotham, Willett, and Ho, Circuit Judges. Don R. Willett, Circuit Judge: Loving County in the heart of Texas’s Permian Basin is the least- populous county in the continental United States. (It was, fittingly, the last county in America to report a case of COVID-19.) But what it lacks in population, it makes up for in petroleum. Sitting atop some of the nation’s richest oil and gas reserves, this patch of West Texas—where pump jacks outnumber people—has long been home to bitter feuds among powerful families vying for political control over a massive tax base swollen by sky-high land values.

1 Case: 23-50850 Document: 66-1 Page: 2 Date Filed: 08/01/2025

No. 23-50850

Three registered Texas voters allege that three local officials—a justice of the peace, a sheriff, and a constable—orchestrated a vengeful scheme to punish them as “personal and political adversaries.” The facts are striking: Plaintiffs reported for jury duty only to be arrested and accused of falsely claiming eligibility by not actually residing in Loving County. Beneath it all lies a deeper battle over election integrity. Plaintiffs cast their votes in Loving County, but officials insist they don’t live there. The officials contend they were merely enforcing Texas voter-eligibility rules and reining in non- residents who are skirting those rules in order to sway elections. Plaintiffs, by contrast, call it “lawfare,” plain and simple—an abuse of law enforcement to settle political scores in a county where near-perfect turnout means elections are often decided by a handful of votes. In their telling, the arrests were a voter-roll ruse—a retaliatory scheme dressed up as voter enforcement, designed to silence dissent and avenge long-simmering personal and political grievances. Weighty though they are, those voter-eligibility disputes—what counts as “residency” and who may vote where—are not before us. This case turns, instead, on a narrower yet no less consequential question: judicial immunity. Plaintiffs sued under § 1983, alleging that their arrests violated a host of constitutional rights. The district court granted judicial and quasi-judicial immunity on some claims but denied judicial immunity for actions tied to what Plaintiffs call a sham jury proceeding. Both sides now appeal. The officials seek reversal of the district court’s denial of judicial immunity for the jury proceeding. Plaintiffs, on cross-appeal, contest the court’s grant of immunity on other claims. We agree with the officials: presiding over the jury proceeding was a judicial act shielded by absolute judicial immunity. As for Plaintiffs’ cross-appeal, we lack jurisdiction to review those claims at this interlocutory stage. We thus REVERSE in part (due to judicial immunity) and DISMISS in part (due to lack of jurisdiction).

2 Case: 23-50850 Document: 66-1 Page: 3 Date Filed: 08/01/2025

I At the pleadings stage, we accept all well-pleaded facts as true and view them in the light most favorable to the plaintiffs. 1 The complaint alleges the following: Loving County is Texas’s least-populous county, home to fewer than 60 residents. A recent surge in oil and gas drilling has driven county revenue to historic highs. Unsurprisingly, the battle for local political control has intensified. The parties here are, by all accounts, “personal and political adversaries.” On one side are the plaintiffs—Matthew Jones, Ysidro Renteria, and William Carr—all registered voters in Loving County. On the other, are three local officials: Justice of the Peace Amber King, Sheriff Chris Busse, and Constable Brandon Jones. 2 This case is but the latest chapter in their long-running feud. According to the complaint, the alleged conspiracy began in 2022, when Judge King informed the county clerk that she needed a jury “for an upcoming trial” and summoned a panel of prospective jurors. Plaintiffs joined other registered voters in a meeting room inside the courthouse annex. No case was called. There were no court reporters, no parties, and no counsel present. Judge King addressed the group and told them that anyone not “qualified” to serve could leave voluntarily. She warned that those who

_____________________ 1 Davis v. Tarrant County, 565 F.3d 214, 217 (5th Cir. 2009) (quotations and citation omitted). 2 For clarity, we refer to Matthew Jones as “Jones” and Brandon Jones as “Constable Jones.”

3 Case: 23-50850 Document: 66-1 Page: 4 Date Filed: 08/01/2025

remained without being “qualified jurors” would be referred to the district attorney for aggravated perjury—a third-degree felony—and held in contempt of court. No one left. The group was then sworn in, pledging to answer Judge King’s questions about their “service and qualifications as a juror” truthfully. Judge King asked the panel about their age, literacy, citizenship, criminal history, and residency. Each confirmed their eligibility, including being a resident of Loving County. Judge King then declared it had “come to [her] attention [that] there are several jurors”—namely, Plaintiffs—“who are not residents” of Loving County. Because they had not left at the outset of voir dire, Judge King held them in contempt and ordered them jailed for obstruction of justice. Constable Jones and a deputy sheriff escorted Plaintiffs into the hallway. They were handcuffed, jailed for five hours, and disqualified from jury service in Loving County. Plaintiffs then filed suit. They allege that the officials orchestrated these events in calculated retaliation for Plaintiffs’ political opposition—thus violating, and conspiring to violate, a range of constitutional rights. The officials moved to dismiss, invoking judicial and quasi-judicial immunity. The district court granted the motion in part and denied it in part. The court held that Judge King was entitled to judicial immunity for issuing contempt orders but not for conducting the jury proceeding. It likewise extended quasi-judicial immunity to Sheriff Busse and Constable Jones for executing those contempt orders. The court dismissed all related claims. In sum, the only claims are those arising from the jury proceeding. The officials appealed the district court’s refusal to dismiss certain claims, and Plaintiffs cross-appealed the dismissal of others.

4 Case: 23-50850 Document: 66-1 Page: 5 Date Filed: 08/01/2025

II We begin with the officials’ primary appeal—one squarely within our jurisdiction. 3 They contend the district court erred in two respects: (1) in declining judicial immunity to Judge King for presiding over the jury proceeding, and (2) in refusing to dismiss the conspiracy claim in its entirety. We review both arguments de novo. 4 A The officials argue that Judge King is entitled to judicial immunity for her role in presiding over the jury proceeding. We agree. “It is well established that judges enjoy absolute immunity for judicial acts performed in judicial proceedings.” 5 Indeed, “immunity applies even when the judge is accused of acting maliciously and corruptly.” 6 There are two—and only two—circumstances in which immunity yields: 7 when a judge acts outside her judicial capacity, 8 or when she acts in the clear absence of all jurisdiction. 9 No party argues that Judge King acted without jurisdiction.

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Jones v. King, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jones-v-king-ca5-2025.