Williamson v. Walton

CourtDistrict Court, District of Columbia
DecidedNovember 21, 2025
DocketCivil Action No. 2025-2706
StatusPublished

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

Bluebook
Williamson v. Walton, (D.D.C. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

JEFF H. WILLIAMSON, ) ) Plaintiff, ) ) Civil Action No. 1:25-cv-02706 (UNA) ) REGGIE B. WALTON, et al., ) ) Defendants. )

MEMORANDUM OPINION

This matter is before the Court on its initial review of Plaintiff’s pro se Complaint

(“Compl.”), ECF No. 1, and his Application for Leave to Proceed in forma pauperis (“IFP”), ECF

No. 2. The Court grants the IFP Application, and for the reasons explained below, it dismisses

this matter without prejudice.

Plaintiff, a federal prisoner currently designated to FCI Butner, seeks over $3 million in

damages arising from alleged constitutional violations committed against him during yet-active

criminal proceedings filed against him in this District. See Compl. at 1, 36–72; see also USA v.

Williamson, No. 20-cr-00195 (RBW) (D.D.C. filed Sept. 17, 2020) (“Williamson I”). 1 He sues the

presiding District Judge, the Offices of the United States Attorneys––including the former U.S.

Attorney for the District of Columbia and the attorneys from that office who are prosecuting him.

See id. at 1–2. He alleges Defendants, and other government actors and entities, have conspired

against him to conduct unlawful mental competency and safety evaluations. See id. at 1, 36–72.

First, the as noted, Williamson I is still active. “Considerations of comity and orderly

administration of justice dictate that two courts of equal authority should not hear the same case

1 A court may take judicial notice of the docket, submissions, and facts on the public record in other court proceedings. See Covad Commc'ns Co. v. Bell Atl. Corp., 407 F.3d 1220, 1222 (D.C. Cir. 2005). simultaneously.” Washington Metro. Area Transit Auth. v. Ragonese, 617 F.2d 828, 830 (D.C.

Cir. 1980) (citing Hilton Hotels Corp. v. Weaver, 325 F.2d 1010, 1010 (D.C. Cir. 1963) (per

curiam), cert. denied, 376 U.S. 951 (1964)). Assuming arguendo that this Court could hear this

case, Plaintiff has also filed an appeal challenging, inter alia, the evaluations at issue in Williamson

I, and the appeal is still pending before the D.C. Circuit. See USA v. Williamson, App. No. 24-

3014 (D.C. Cir. filed July 29, 2025). “The relationship between district court jurisdiction and the

issuance of the appeals court mandate is clear and well-known: The filing of a notice of appeal,

including an interlocutory appeal, confers jurisdiction on the court of appeals and divests the

district court of control over those aspects of the case involved in the appeal.” Griggs v. Provident

Consumer Discount Co., 459 U.S. 56, 58 (1982) (per curiam) (citation omitted). The district court

does not regain jurisdiction over those issues until the court of appeals issues its mandate. Johnson

v. Bechtel Associates Professional Corp., 801 F.2d 412, 415 (D.C. Cir. 1986) (per curiam). The

D.C. Circuit has yet to issue a mandate in response to Plaintiff’s appeal; therefore, this Court is

doubly prohibited from reviewing the actions taken in Williamson I.

Second, judges are absolutely immune from suits for money damages for “all actions taken

in the judge’s judicial capacity, unless these actions are taken in the complete absence of all

jurisdiction.” Sindram v. Suda, 986 F.2d 1459, 1460 (D.C. Cir. 1993); see also Mireles v.

Waco, 502 U.S. 9, 9 (1991) (acknowledging that a long line of Supreme Court precedents have

found that a “judge is immune from a suit for money damages”); Caldwell v. Kagan, 865 F. Supp.

2d 35, 42 (D.D.C. 2012) (“Judges have absolute immunity for any actions taken in a judicial or

quasi-judicial capacity.”). And “a judge will not be deprived of immunity because the action he

took was in error, was done maliciously, or was in excess of his authority. Stump v. Sparkman, 435

U.S. 349, 356 (1978); see also Mireles, 502 U.S. at 11 (“[J]udicial immunity is not overcome by allegations of bad faith or malice.”). Because the actions alleged by Plaintiff were taken in the

presiding judge’s official capacity, he is absolutely immune from suit.

Similarly, unless a prosecutor proceeds in the clear absence of all jurisdiction, absolute

immunity exists for those prosecutorial activities intimately associated with the judicial phase of

the criminal process.” Gray v. Bell, 712 F.2d 490, 499 (D.C. Cir.1983) (absolute prosecutorial

immunity for even quasi-judicial actions), cert. denied, 465 U.S. 1100 (1984). Here, the alleged

involvement of the prosecutorial defendants arises directly from their roles in prosecuting plaintiff.

Judicial and quasi-judicial activities clearly include the initiation of a prosecution and the

presentation of the government’s case. See id.; Imbler v. Pachtman, 424 U.S. 409 (1976);

Expeditions Unlimited Aquatic Enter., Inc. v. Smithsonian Inst., 566 F.2d 289, 292 (D.C. Cir.

1977).

The Court also notes that it finds no merit in Plaintiff’s contentions that the Defendants

have engaged in a multifaceted conspiracy to cause his harm, and such allegations do not suffice

to overcome the high hurdle of immunity. See Curran v. Holder, 626 F. Supp. 2d 30, 34 (D.D.C.

2009) (finding that the plaintiff’s “laundry list of wrongful acts and conclusory allegations to

support h[is] theory of a conspiracy,” were patently “insufficient to allow the case to go forward.”)

(citation omitted).

Finally, the Court denies Plaintiff’s Motion to Correct Record for the Filing Date of the

Lawsuit, ECF No. 4. In the Motion, Plaintiff demands that the Court change the date of this

matter’s filing to the date that it was entered by the Clerk, September 15, 2025, rather than the date

it was received, on August 14, 2025, and he believes that this “backdating” is borne from a

conspiracy by the Court to dismiss this case based on failure to effect timely service of process,

see id. at 1–3. Apart from the frivolousness of these arguments, Plaintiff is mistaken. Under the Federal Rules of Civil Procedure, a complaint is generally filed when it is delivered to the Clerk.

See Morrison v. Nielsen, 325 F. Supp. 3d 62, 66 (D.D.C. 2018) (citing Moore v. Agency for Int’l

Dev., 994 F.2d 874, 876 (D.C. Cir. 1993)). Accordingly, August 14, 2025, the date that this matter

was delivered to the Clerk, is the correct date of filing. See Compl. at 1 (reflecting Aug. 14, 2025

date stamp).

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Related

Imbler v. Pachtman
424 U.S. 409 (Supreme Court, 1976)
Stump v. Sparkman
435 U.S. 349 (Supreme Court, 1978)
Griggs v. Provident Consumer Discount Co.
459 U.S. 56 (Supreme Court, 1982)
Mireles v. Waco
502 U.S. 9 (Supreme Court, 1991)
L. Patrick Gray, III v. Griffin Bell
712 F.2d 490 (D.C. Circuit, 1983)
William L. Mondy v. Secretary of the Army
845 F.2d 1051 (D.C. Circuit, 1988)
Curran v. Holder
626 F. Supp. 2d 30 (District of Columbia, 2009)
Caldwell v. Kagan
865 F. Supp. 2d 35 (District of Columbia, 2012)
Morrison v. Nielsen
325 F. Supp. 3d 62 (D.C. Circuit, 2018)

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