MacNeil v. Harris

CourtDistrict Court, D. Idaho
DecidedSeptember 10, 2024
Docket1:24-cv-00063
StatusUnknown

This text of MacNeil v. Harris (MacNeil v. Harris) is published on Counsel Stack Legal Research, covering District Court, D. Idaho primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MacNeil v. Harris, (D. Idaho 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF IDAHO

DUDLEY MACNEIL, Case No. 1:24-cv-000063-DCN Plaintiff, INITIAL REVIEW ORDER v. BY SCREENING JUDGE

JUDGES HARRIS AND BUTLER, TWIN FALLS COUNTY IDOC DISTRICT 5, KIRSTEN CLAGLE, AND JEREMY THOMAS,

Defendants.

The Complaint of Plaintiff Dudley MacNeil was conditionally filed by the Clerk of Court due to his status as a prisoner and pauper. Dkts. 3, 1. To state a claim under 42 U.S.C. § 1983, the civil rights statute, a plaintiff must allege a violation of rights protected by the Constitution or created by federal statute proximately caused by conduct of a person acting under color of state law. Crumpton v. Gates, 947 F.2d 1418, 1420 (9th Cir. 1991). All conditionally-filed prisoner complaints must be screened by the Court to determine whether summary dismissal is appropriate. 28 U.S.C. §§ 1915 & 1915A. The Court must dismiss any claims that state a frivolous or malicious claim, fail to state a claim upon which relief may be granted, or seek monetary relief from a defendant who is immune from such relief. 28 U.S.C. § 1915(e)(2)(B). After reviewing the Complaint, the Court has determined that Plaintiff must file an amended complaint with additional facts or a notice of voluntary dismissal if he does not have sufficient facts to state a claim. REVIEW OF COMPLAINT

1. Claims against State Court Judges Plaintiff alleges that Judge Harris and Judge Butler “are not wise men”; “are not capable and honest men who fear God”; that they “take bribes”; and that they have been “breaking” various Idaho Administrative Procedures. Dkt. 3 at 2. Plaintiff has not provided facts showing that judicial immunity would not apply to the judges’ acts.

Under the doctrine of absolute judicial immunity, a judge is not liable for monetary damages for acts performed in the exercise of judicial functions. Stump v. Sparkman, 435 U.S. 349 (1978). To determine whether an act is judicial in nature so that immunity would apply, a court looks to “the nature of the act itself, i.e., whether it is a function normally performed by a judge, and to the expectations of the parties, i.e., whether they dealt with

the judge in his judicial capacity.” Id. at 362. Once it is determined that a judge was acting in his or her judicial capacity, absolute immunity applies, “however erroneous the act may have been, and however injurious in its consequences it may have proved to the plaintiff.” Ashelman v. Pope, 793 F.2d 1072, 1075 (9th Cir. 1986) (internal citations omitted). For example, judicial immunity is not lost “by allegations that a judge conspired with one party to rule against another party: ‘a conspiracy

between judge and [a party] to predetermine the outcome of a judicial proceeding, while clearly improper, nevertheless does not pierce the immunity extended to judges.’” Moore v. Brewster, 96 F.3d 1240, 1244 (9th Cir. 1996) (superseded by statute on other grounds) (quoting Ashelman, 793 F.2d at 1078). In addition, “judicial immunity is not overcome by allegations of bad faith or malice.” Mireles v. Waco, 502 U.S. 9, 11 (1991). “[W]here the alleged harm, though

resulting from a bribe or conspiracy, was inflicted by acts to which absolute immunity would apply, the complaint is insufficient to avoid judicial immunity.” Ashelman, 793 F.2d at 1077 (citation and punctuation omitted); see Dennis v. Sparks, 449 U.S. 24, 27 (1980) (finding judge was properly dismissed from § 1983 case on immunity grounds where alleged bribery occurred between private parties and the judge). Although these decisions

may seem unfair, the American judicial system provides absolute immunity for judicial officers because immunity “is justified and defined by the functions it protects and serves, not by the person to whom it attaches.” Forrester v. White, 484 U.S. 219, 227 (1988). There are two circumstances in which absolute judicial immunity does not apply. First, a judge may not rely on immunity when he or she performs an act that is not “judicial”

in nature. Stump, 435 U.S. at 360. For example, when a judge used physical force to evict a person from the courtroom, the Ninth Circuit held that the judge performed a nonjudicial act not covered by absolute immunity. Gregory v. Thompson, 500 F.2d 59, 63 (9th Cir. 1974). On the other hand, when a judge ordered officers “to forcibly and with excessive force seize and bring plaintiff into his courtroom,” judicial immunity applied, because a

“judge’s direction to court officers to bring a person who is in the courthouse before him is a function normally performed by a judge.” Mireles, 502 U.S. at 12. Second, absolute immunity does not apply when a judge acts in “the clear absence of all jurisdiction.” Stump, 435 U.S. at 356 (internal citations omitted). The question of whether a judge acted in excess of authority in making a judicial ruling is a distinct issue from the question of whether a judge acted in the clear absence of jurisdiction. Even if a judge exceeds his authority in making a judicial ruling in a particular case, that judge is

immune if the case is properly before him. Mireles, 502 U.S. at 13. The difference between acting in the absence of jurisdiction and acting in excess of authority is made clear in the following example: “if a probate judge, with jurisdiction over only wills and estates, should try a criminal case, he would be acting in the clear absence of jurisdiction and would not be immune from liability for his action; on the other hand, if

a judge of a criminal court should convict a defendant of a nonexistent crime, he would merely be acting in excess of his jurisdiction and would be immune.” Stump, 435 U.S. at 357. In Idaho, the state district courts have original jurisdiction over all cases and proceedings in law and in equity. I.C. § 1-705; Idaho Const. art. V, § 20. The jurisdiction

of magistrate judges “is established by legislation, I.C. §§ 1-2208, 1-2210; under the Idaho Constitution, ID. Const. art. 5, § 2; by rule of the Idaho Supreme Court, I.R.C.P. 82; and by the rules of the respective district courts, e.g., 4th Judicial District Court Rule 3.0 (1979).” Marks v. Vehlow, 671 P.2d 473, 476 (Idaho 1983). District court and magistrate judges have jurisdiction to hear criminal misdemeanor

and quasi-criminal actions. I. C. § 1-705; I.C. § 1-2208. By statute, state magistrate judges may be assigned to preside over “[p]roceedings for the preliminary examination to determine probable cause, commitment prior to trial or the release on bail of persons charged with criminal offenses.” I.C. § 1-2208(3)(d).

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Related

Preiser v. Rodriguez
411 U.S. 475 (Supreme Court, 1973)
Johnson v. Railway Express Agency, Inc.
421 U.S. 454 (Supreme Court, 1975)
Stump v. Sparkman
435 U.S. 349 (Supreme Court, 1978)
Dennis v. Sparks
449 U.S. 24 (Supreme Court, 1980)
Parratt v. Taylor
451 U.S. 527 (Supreme Court, 1981)
Hudson v. Palmer
468 U.S. 517 (Supreme Court, 1984)
Daniels v. Williams
474 U.S. 327 (Supreme Court, 1986)
Forrester v. White
484 U.S. 219 (Supreme Court, 1988)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
Heck v. Humphrey
512 U.S. 477 (Supreme Court, 1994)
Wilkinson v. Dotson
544 U.S. 74 (Supreme Court, 2005)
Douglas Gregory v. John J. Thompson
500 F.2d 59 (Ninth Circuit, 1974)
Wilhelm v. Frampton
158 P.3d 310 (Idaho Supreme Court, 2007)
J.R. Simplot Co. v. Chemetics International, Inc.
887 P.2d 1039 (Idaho Supreme Court, 1994)
Herrera v. Conner
729 P.2d 1075 (Idaho Court of Appeals, 1987)
Limbert v. Twin Falls County
955 P.2d 1123 (Idaho Court of Appeals, 1998)
Marks v. Vehlow
671 P.2d 473 (Idaho Supreme Court, 1983)
Duane Belanus v. Phil Clark
796 F.3d 1021 (Ninth Circuit, 2015)

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MacNeil v. Harris, Counsel Stack Legal Research, https://law.counselstack.com/opinion/macneil-v-harris-idd-2024.