Wanda Bowling v. John Roach

Summary

Fifth Circuit affirmed dismissal of pro se §1983 claims against a state judge for divorce decree enforcement. Official-capacity claims were barred by Eleventh Amendment sovereign immunity, and the Ex Parte Young exception did not apply because no ongoing federal violation was alleged. Individual-capacity claims for injunctive relief were barred by Younger abstention due to pending state proceedings implicating important family-law interests, and damages claims were barred by judicial immunity.

Holdings

1. Claims against Judge Roach in his official capacity are barred by the Eleventh Amendment because Bowling did not allege an ongoing violation of federal law, so the Ex Parte Young exception does not apply.
2. Younger abstention bars claims for injunctive relief against Judge Roach in his individual capacity because there is an ongoing state proceeding, important state interest in family law, and adequate opportunity to raise federal claims.
3. Judicial immunity bars damages claims against Judge Roach because his actions were judicial in nature and he did not act in the complete absence of jurisdiction.

Questions Presented

1. Whether claims against Judge Roach in his official capacity are barred by the Eleventh Amendment.
2. Whether the Younger abstention doctrine bars claims for injunctive relief against Judge Roach in his individual capacity.
3. Whether judicial immunity bars damages claims against Judge Roach.

Disposition

affirmed