Edward Hoid v. Thomas F. Neville; Bree Derrick

Summary

The United States District Court for the District of Idaho grants Edward Hoid leave to proceed in forma pauperis but dismisses his claims against a former state judge and the Idaho Department of Correction executive director. The court concludes that the claims against the judge are barred by absolute judicial immunity and that the claims against the executive director fail for lack of personal involvement and are time-barred. The court also denies leave to amend as futile, denies a motion to compel as moot, and dismisses the action with prejudice.

Holdings

1. Hoid demonstrated an inability to pay the filing fee and was permitted to proceed in forma pauperis.
2. Judge Neville was entitled to absolute judicial immunity from damages claims because the challenged conduct consisted of judicial acts performed in a case properly before a court of competent jurisdiction.
3. Hoid failed to state a viable claim against Derrick individually because the complaint did not allege her personal involvement in his incarceration or medical treatment, and § 1983 does not impose respondeat superior liability.
4. Official-capacity damages claims against Derrick were barred because a state officer sued for damages in her official capacity is not a person for purposes of § 1983 and the statute does not waive state sovereign immunity.
5. Hoid's § 1983 claims were barred by Idaho's two-year statute of limitations because the claims accrued when he knew or had reason to know of the alleged injuries during his earlier periods of incarceration, not when he later suspected a legal wrong or received a later diagnosis.
6. Hoid's ADA claim was also time-barred because the alleged disability-related injuries occurred during incarceration years before the complaint was filed and the limitations period was not restarted by later diagnosis or complications.
7. Leave to amend was properly denied because amendment would be futile and could not cure judicial immunity, sovereign-immunity and official-capacity defects, lack of personal involvement, and untimeliness.

Questions Presented

1. Whether Hoid could proceed in forma pauperis.
2. Whether claims for damages against Judge Neville were barred by absolute judicial immunity.
3. Whether claims against Derrick were barred or deficient because the complaint did not allege her personal involvement, official-capacity damages claims were barred, and the claims were untimely.
4. Whether Hoid's constitutional, § 1983, and ADA claims were barred by the applicable statutes of limitations.
5. Whether amendment would be futile and therefore could be denied without leave to amend.
6. Whether the motion to compel should be denied as moot after dismissal of the action.

Disposition

dismissed