Joseph L. Jones v. State of Washington, Washington State Department of Corrections, Jenna Knox, John/Jane Does 1-10

CourtDistrict Court, W.D. Washington
DecidedJanuary 14, 2026
Docket2:25-cv-01696
StatusUnknown

This text of Joseph L. Jones v. State of Washington, Washington State Department of Corrections, Jenna Knox, John/Jane Does 1-10 (Joseph L. Jones v. State of Washington, Washington State Department of Corrections, Jenna Knox, John/Jane Does 1-10) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joseph L. Jones v. State of Washington, Washington State Department of Corrections, Jenna Knox, John/Jane Does 1-10, (W.D. Wash. 2026).

Opinion

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5 UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE 7 8 JOSEPH L. JONES, 9 Plaintiff, CASE NO. 2:25-cv-01696-KKE-BAT 10 v. ORDER OF DISMISSAL 11 STATE OF WASHINGTON, WASHINGTON STATE DEPARTMENT 12 OF CORRECTIONS, JENNA KNOX, JOHN/JANE DOES 1-10, JOHN/JANE 13 DOES 1–10, 14 Defendants.

15 I. INTRODUCTION

16 This matter comes before the Court on United States Magistrate Judge Brian A. Tsuchida’s 17 report and recommendation (“R&R”) to dismiss Plaintiff Joseph L. Jones’s complaint. Dkt. No. 18 23. Jones was convicted of one count of rape of a child in the first degree in 2010 in King County 19 Superior Court in Washington. Id. at 2. After he was released from state prison in 2019, he began 20 a lifetime term of community custody. Id. Community custody is a form of supervised release 21 allowing individuals to serve part of their sentence in the community instead of in prison. Id. 22 Individuals in community custody must adhere to certain court-imposed conditions under 23 supervision by a community corrections officer. Jones brought this suit against the State of Washington, Washington State Department of Corrections, former community corrections officer 1 Jenna Knox, and unnamed Department of Corrections employees, challenging the constitutionality 2 of the conditions of his community custody. 3 The R&R recommends dismissing Jones’s complaint with prejudice based on two 4 alternative grounds: immunity and the doctrine of Younger abstention. Having reviewed de novo

5 the R&R, Jones’s objections to the R&R (Dkt. Nos. 24), and the remaining record, the Court adopts 6 the R&R’s recommendation to dismiss Jones’s claims on the basis of absolute immunity. Because 7 immunity disposes of Jones’s complaint, the Court will not reach the issue of whether it must 8 abstain under Younger v. Harris, 401 U.S. 37 (1971). 9 II. ANALYSIS 10 A. Defendants are immune from Jones’s suit. 11 The R&R finds that sovereign immunity bars Jones’s claims against the state entity 12 defendants and absolute quasi-judicial immunity bars his claims for damages against former 13 Department of Corrections employee Jenna Knox.1 The R&R further concludes that to the extent 14 Jones seeks prospective injunctive relief under the immunity exception recognized in Ex parte

15 Young, 209 U.S. 123 (1908), his claim fails because he alleges Knox is no longer a community 16 corrections officer; therefore, no injunctive relief is necessary or possible. Finally, the R&R finds 17 that Jones’s claims against unnamed John and Jane Doe defendants are barred by immunity (to the 18 extent they are sued in their official capacities) and because Jones fails to allege how each 19 defendant personally participated in the alleged misconduct (to the extent they are sued in their 20 individual capacities). 21

22 1 As the R&R observes, the complaint does not state whether Knox is sued in her official or individual capacity, but she is immune either way. If sued in her official capacity, Knox enjoys Eleventh Amendment immunity as an 23 officer of a state agency. Quern v. Jordan, 440 U.S. 332, 342 (1979). If sued in her individual capacity, she enjoys absolute quasi-judicial immunity. Swift v. California, 384 F.3d 1184, 1189 (9th Cir. 2004); see Gay v. Parsons, No. 16-CV-05998-CRB, 2019 WL 3387954, at *3 (N.D. Cal. July 26, 2019), aff’d, 810 F. App’x 552 (9th Cir. 2020). 1 First, Jones’s objections do not address the R&R’s immunity analysis with respect to the 2 state entity defendants or the unnamed John and Jane Doe defendants. Instead, Jones focuses on 3 the applicability of the Ex parte Young doctrine and quasi-judicial immunity to his claims against 4 Knox. To the extent Jones intends to invoke Ex parte Young for his claims against “[t]he State

5 and [the Department of Corrections]” (Dkt. No. 24 at 3), the Ex parte Young doctrine does not 6 extend to claims against the State or its agencies. See, e.g., Nat’l Audubon Soc’y Inc. v. Davis, 307 7 F.3d 835, 847 (9th Cir. 2002) (“[T]he … state agencies are also immune from suit because they 8 are state entities, not individual state officers.”); In re Lazar, 237 F.3d 967, 976 n.9 (9th Cir. 2001) 9 (Ex parte Young doctrine “inapposite” where plaintiff sued only the state entity rather than “the 10 appropriate [state] officers”); Douglas v. Cal. Dept. of Youth Authority, 271 F.3d 812, 821 n.6 (9th 11 Cir. 2001) (“Because [the plaintiff] has not named a state official as a defendant in this suit, the Ex 12 parte Young doctrine does not apply.”). 13 With respect to his claim against Knox in her official capacity, Jones’s objections clarify 14 that he intends to advance a claim for injunctive relief under Ex parte Young. But he fails to

15 respond to the R&R’s observation that the only state officer identified in his complaint, Knox, is 16 no longer a community corrections officer. A “proper defendant[]” in an Ex parte Young action 17 must be an official whose responsibilities have both “the requisite causal connection” to the 18 plaintiff’s injury and “some connection” to the “enforcement of a challenged state law.” Loffman 19 v. Cal. Dep’t of Educ., 119 F.4th 1147 (9th Cir. 2024) (quoting Planned Parenthood of Idaho, Inc. 20 v. Wasden, 376 F.3d 908, 919 (9th Cir. 2004)). A former officer satisfies neither requirement. 21 Therefore, Jones’s claim for injunctive relief pursuant to Ex parte Young must be dismissed. 22 Jones also objects that Knox is not entitled to absolute quasi-judicial immunity in her 23 individual capacity because her challenged conduct involved “administrative” rather than 1 “judicial” functions. Dkt. No. 24 at 2. This argument is foreclosed by Ninth Circuit precedent, 2 which holds that the “imposition of parole conditions” is a quasi-judicial function subject to 3 absolute immunity. Swift v. California, 384 F.3d 1184, 1189 (9th Cir. 2004) (quoting Anderson v. 4 Boyd, 714 F.2d 906, 909 (9th Cir. 1983)). The imposition of conditions with respect to Jones’s

5 community custody is indistinguishable in any relevant way from the imposition of parole 6 conditions. 7 Because Knox is entitled to absolute quasi-judicial immunity against suit in her individual 8 capacity and Jones cannot sue under the Ex parte Young exception to official immunity, the Court 9 rejects Jones’s objections to the R&R’s immunity analysis. 10 B. The Court does not reach the alternative ruling applying Younger abstention. 11 The R&R also recommends dismissal on the alternative ground that the doctrine of 12 Younger abstention bars Jones’s claims because “the state proceeding in which [he] was convicted 13 … is ongoing” and on appeal. Dkt. No. 23 at 5–6. The Ninth Circuit has called Younger abstention 14 “an extraordinary and narrow exception to the general rule that federal courts” are obliged to

15 “exercise … jurisdiction which is given” to them. Cook v. Harding, 879 F.3d 1035, 1038 (9th Cir. 16 2018) (quoting Nationwide Biweekly Admin., Inc. v.

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Related

Ex Parte Young
209 U.S. 123 (Supreme Court, 1908)
Younger v. Harris
401 U.S. 37 (Supreme Court, 1971)
Quern v. Jordan
440 U.S. 332 (Supreme Court, 1979)
Anderson v. Boyd
714 F.2d 906 (Ninth Circuit, 1983)
United States v. William R. Wilson
7 F.3d 828 (Ninth Circuit, 1993)
Matter of Personal Restraint of St. Pierre
823 P.2d 492 (Washington Supreme Court, 1992)
Nationwide Biweekly Administration, Inc. v. Owen
873 F.3d 716 (Ninth Circuit, 2017)
Melissa Cook v. Cynthia Harding
879 F.3d 1035 (Ninth Circuit, 2018)
Sprint Commc'ns, Inc. v. Jacobs
134 S. Ct. 584 (Supreme Court, 2013)
Planned Parenthood of Idaho, Inc. v. Wasden
376 F.3d 908 (Ninth Circuit, 2004)
Jonathan Duke v. Josie Gastelo
64 F.4th 1088 (Ninth Circuit, 2023)
Chaya Loffman v. California Department of Education
119 F.4th 1147 (Ninth Circuit, 2024)

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Bluebook (online)
Joseph L. Jones v. State of Washington, Washington State Department of Corrections, Jenna Knox, John/Jane Does 1-10, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joseph-l-jones-v-state-of-washington-washington-state-department-of-wawd-2026.