Summary
This Memorandum and Order from the U.S. District Court for the District of Massachusetts addresses multiple motions to dismiss filed by defendants in a civil rights lawsuit brought under 42 U.S.C. § 1983. The court grants the motions to dismiss, holding that state court defendants are protected by Eleventh Amendment sovereign immunity and quasi-judicial immunity, while individual defendants failed to act under color of state law or form a civil rights conspiracy. The court also denies plaintiffs' requests for injunctive relief against judicial officers and their attempt to vacate state court judgments under Federal Rule of Civil Procedure 60(b).
Topics
Practice areas
Questions Presented
- Whether the State Court Defendants are barred by sovereign and quasi‑judicial immunity from §1983 claims.
- Whether the Individual Defendants' motion to dismiss for failure to state a §1983 claim should be granted.
- Whether the civil‑rights conspiracy claim should be dismissed.
- Whether the fraud‑on‑the‑court claim should be dismissed.
- Whether the Individual Defendants are entitled to attorneys' fees.
- Whether the motion to preclude further filings by the Cottrells should be granted.
- Whether the motions to consolidate, stay remand, and enjoin the state‑court proceeding should be denied as moot.
Holdings
- The State Court Defendants are immune from §1983 liability because the Superior Court is an instrumentality of the State and its clerks are entitled to sovereign and quasi‑judicial immunity.
- The motion to dismiss is granted because the complaint fails to allege that the Individual Defendants acted under color of law.
- The motion to dismiss is granted because the complaint lacks specific facts showing an agreement between the Individual Defendants and the Clerks to deprive the plaintiffs of civil rights.
- The motion to dismiss is granted because the allegations do not rise to the level of fraud on the court required for a claim.
- The request for attorneys' fees is denied because the claims are not patently frivolous or unfounded.
- The motion is granted; the Cottrells may not file further pleadings without leave of court.
- All three motions are denied as moot because the related cases are closed and the district court lacks authority to act on them.
Key quotations
““SLAPP suits are “generally meritless suits … to deter common citizens from exercising their political or legal rights or to punish them for doing so.””
Factual background
The dispute arose from a contract between the Cottrells and Mann and Cote. Mann and Cote filed a state‑court suit alleging violations of Mass. Gen. L. c. 93A. They later served a special SLAPP motion under Superior Court Rule 9A, which the Cottrells contested. The parties exchanged ex‑parte communications with court clerks, and the Superior Court entered a sanction order. The Cottrells removed the case to federal court, and the defendants moved to dismiss the federal complaint.
Procedural history
The Cottrells filed a civil rights action in this Court after removal from a Massachusetts Superior Court case involving a contractual dispute and alleged SLAPP motion. The parties filed numerous motions, including motions to dismiss, to strike, and for attorneys' fees. The Court considered the motions and issued this memorandum and order.