Eric Miller v. Thirteenth District Court of Sandoval County, James A. Noel, Marcy Baysinger and Kamil Woods

Summary

The United States District Court for the District of New Mexico dismissed without prejudice a pro se plaintiff’s claims arising from a state-court probate proceeding. The court held that claims against the state district court and judge were barred by sovereign or judicial immunity, and that claims against the private probate participant and her attorney failed to allege action under color of state law. After dismissing the federal claims, the court declined supplemental jurisdiction over the state-law claims.

Holdings

1. The claims against the Thirteenth Judicial District Court and Judge Noel in his official capacity were barred because the complaint did not allege state consent, congressional abrogation, or an applicable Ex parte Young exception.
2. Judge Noel was entitled to absolute judicial immunity because plaintiff did not allege that the judge acted in the complete absence of all jurisdiction.
3. Plaintiff failed to state § 1983 claims against Woods and Baysinger because the second amended complaint did not allege that either defendant acted under color of state law.
4. The court declined to exercise supplemental jurisdiction over plaintiff's state-law claims after dismissing all claims over which it had original jurisdiction.

Questions Presented

1. Whether claims against the state district court and Judge Noel in his official capacity were barred by Eleventh Amendment sovereign immunity.
2. Whether Judge Noel was entitled to absolute judicial immunity from claims against him in his individual capacity.
3. Whether plaintiff stated a claim under 42 U.S.C. § 1983 against Woods and Baysinger by alleging action under color of state law.
4. Whether the court should exercise supplemental jurisdiction over the state-law claims after dismissing all federal claims.

Disposition

dismissed