Logan Martin Isaac v. James Ivory Manning, Jr., Shelly Boshart Davis, Renee Perry, and John and Jane Does 1–10

Summary

The United States District Court for the District of Oregon screens Logan Martin Isaac’s Second Amended Complaint alleging First Amendment retaliation, Fourteenth Amendment procedural due process violations, and conspiracy arising from restrictions on his access to the Oregon Capitol and legislative actions concerning proposed bills. The court concludes that Senator Manning and Representative Davis are entitled to legislative immunity for conduct related to legislative proceedings, while claims concerning Capitol access restrictions may minimally survive screening against Representative Davis, Renee Perry, and Doe defendants. The court dismisses all claims against Senator Manning without leave to amend and permits prospective injunctive-relief claims under Ex parte Young concerning ongoing Capitol access restrictions.

Holdings

1. Senator Manning's decision not to schedule a hearing on SB 1057 was a legislative act protected by absolute legislative immunity, even if the decision was allegedly motivated by retaliation against Isaac.
2. Isaac's claims against Senator Manning, and his claims against Representative Davis to the extent based on legislative conduct involving cancellation of a hearing on SJM1, were barred by legislative immunity.
3. Isaac's allegations were minimally sufficient at the screening stage to proceed on First Amendment retaliation, Fourteenth Amendment procedural due process, and conspiracy claims against Representative Davis, Renee Perry, and the Doe defendants, including Brett Hanes, insofar as the claims concerned restrictions on access to the Capitol or Davis's office.
4. Isaac plausibly stated a claim for prospective injunctive relief against Representative Davis and Doe defendants to prevent ongoing enforcement of the alleged Capitol and office access restrictions.
5. Ex parte Young does not authorize retrospective money damages against state officials or adjudication of the legality of past conduct.

Questions Presented

1. Whether Senator Manning's refusal to schedule a legislative hearing was protected legislative conduct subject to absolute legislative immunity under 42 U.S.C. § 1983.
2. Whether Isaac plausibly stated First Amendment retaliation, Fourteenth Amendment procedural due process, and civil-rights conspiracy claims based on restrictions on his access to the Capitol and Representative Davis's office.
3. Whether Isaac plausibly stated a claim for prospective injunctive relief under Ex parte Young based on allegedly ongoing enforcement of the access restrictions.
4. Whether the claims against Senator Manning should be dismissed without leave to amend because the defects could not be cured by amendment.

Disposition

other