Sylvia James v. Hilliard Hampton

592 F. App'x 449
CourtCourt of Appeals for the Sixth Circuit
DecidedJanuary 7, 2015
Docket14-1151
StatusUnpublished
Cited by45 cases

This text of 592 F. App'x 449 (Sylvia James v. Hilliard Hampton) is published on Counsel Stack Legal Research, covering Court of Appeals for the Sixth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sylvia James v. Hilliard Hampton, 592 F. App'x 449 (6th Cir. 2015).

Opinions

OPINION

COLE, Chief Judge.

Sylvia James, a former Michigan state court judge, was removed from the bench by the Michigan Supreme Court in 2012 after the state Judicial Tenure Commission (“JTC”) investigated her for financial and other misconduct and recommended her removal. While the investigation was ongoing, James sued the JTC and other state and local officials under 42 U.S.C. § 1983, alleging violations of (1) her Fourth Amendment rights under the United States Constitution stemming from a search of her courthouse office and personal safe and (2) her Fourteenth Amendment equal protection rights under the United States Constitution because the JTC chose not to recommend the discipline of several white Michigan state court judges who also engaged in judicial misconduct. She also alleged various state law claims.

The district court declined to exercise supplemental jurisdiction over the state law claims and dismissed the federal claims under the Younger abstention doctrine because the JTC proceedings against James were ongoing. A panel of our court reversed the district court’s dismissal of the complaint, finding that abstention was proper but that the case should have been stayed instead. On remand, the district court again dismissed the federal claims, this time for failure to state a claim for relief, and declined to reconsider its decision not to exercise supplemental jurisdiction over the state claims. James now appeals the dismissal of her federal claims as well as the decision not to exercise supplemental jurisdiction. For the following reasons, we reverse the district court’s dismissal of James’s Fourth and Fourteenth Amendment claims and affirm the dismissal of her state claims.

I. BACKGROUND

In reviewing a district court’s grant of a motion to dismiss, we construe the complaint in the light most favorable to the plaintiff and accept all allegations as true. Pedreira v. Ky. Baptist Homes for Children, Inc., 579 F.3d 722, 727 (6th Cir.2009). Plaintiff-Appellant Sylvia James, an African-American woman, served as the sole judge of the 22nd District Court in Ink-ster, Michigan, for more than 23 years. In 2010, the Inkster City Council, the funding unit for the 22nd District Court, hired attorney David Jones to investigate James, and in February 2011 he filed a grievance against her with the JTC alleging that James abused her office. Due to Jones’s grievance, the JTC conducted an investigation to determine whether a formal complaint and hearing was warranted.

The Michigan Constitution authorizes the nine-member JTC to oversee the discipline of Michigan’s judiciary. Mich. Const, art. VI, § 30. The JTC investigates grievances against judges in order to determine whether to file a formal complaint. Mich. Ct. R. 9.207(B). If the JTC files a formal complaint, it then conducts a hearing on the matter. Mich. Ct. R. 9.210(A). The Michigan Supreme Court may appoint a master to conduct the hearing and issue a report of his or her findings. Mich. Ct. R. 9.210(B); 9.214. By majority vote, the JTC may then recommend to the Michigan Su[452]*452preme Court that a judge be removed from office or otherwise disciplined. Mich. Ct. R. 9.220(A). The court then considers the recommendation of the JTC as well as a petition and brief submitted by the judge being investigated if she so chooses. Mich. Ct. R. 9.224. Finally, the court files an opinion and judgment, which may accept, reject, or modify the recommendations of the JTC, or orders further evidence to be taken. Mich. Ct. R. 9.225.

During the course of the investigation of the grievance against James, the Michigan Supreme Court voted to place her on administrative leave on April 13, 2011. Compl., R. 1-2, PagelD 68. In May 2011, James met with Defendant Green, the regional administrator for the Michigan Supreme Court Administrator’s Office, to discuss procedures associated with her administrative leave, and she told Green that her safe and office contained personal documents. Green told James that “she would not allow the violation of [James’s] privacy rights and that no one would open her personal safe outside of her presence.” Compl., R. 1, PagelD 7. Sometime after this meeting, Defendants Green and Washington, James’s replacement as chief judge of the 22nd District Court, searched James’s office and safe. James alleges that on June 14, 2011, documents seized during the search were provided to the JTC, but she did not learn of the search until after it was completed. James further alleges that, sometime before the JTC filed its formal complaint, she was allowed one hour to enter her office and retrieve items. When she entered the office, she found that “locks to her personal safe had been dismantled and that many of the documents that would be exculpatory were missing from her office and safe.” Id. at 9.

On October 26, 2011, the JTC filed a formal complaint against James alleging financial, administrative, and employment improprieties, as well as misrepresentations to the JTC during the investigation. In re James, 492 Mich. 553, 558, 821 N.W.2d 144, 148 (2012). In December, the Michigan Supreme Court suspended James with pay and appointed a master, who conducted a formal hearing from January 23, 2012 until March 1, 2012. Id.

Three days before the hearing began, James filed this 42 U.S.C. § 1983 action in the United States District Court for the Eastern District of Michigan, asserting violations of her federal constitutional rights by the following two groups of defendants: (1) Hilliard Hampton, mayor of the City of Inkster; the City of Inkster; David Jones, attorney for the City of Inkster; and Pamela Anderson, court administrator for the 22nd District Court (collectively, “Ink-ster Defendants”); and (2) Deborah Green, regional administrator for the Michigan Supreme Court Administrator’s Office; the JTC; Paul Fischer, executive director of the JTC; and Valdemar Washington, chief judge of the 22nd District Court (collectively, “State Defendants”). She further alleged state claims of defamation (against Hampton), .the right to privacy (against the State Defendants), replevin for the return of her documents (against the State Defendants), and violations of the Michigan Court Rules (against the State Defendants). She also sought a temporary restraining order (“TRO”) against the JTC proceedings.

Specifically, James argued that both the Inkster and State Defendants violated her Fourth Amendment right to be free from unreasonable searches and seizures when they searched her office and broke into her locked personal safe without a warrant or a showing of probable cause. James further contended that these documents were provided to Fischer, the JTC executive director, and to the JTC for use in the [453]*453investigation against her. Finally, James claimed that Anderson, the court administrator for the 22nd District Court, removed and/or destroyed exculpatory evidence from her safe and office.

James also contended that the JTC and Fischer denied her the equal protection of the law guaranteed by the Fourteenth Amendment by disciplining her while failing to initiate disciplinary proceedings against five white Michigan state court judges who had engaged in serious judicial misconduct.

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