Bleauregard Kasadu v. David Connell; Michael Wu; Scott Management, LLC

Summary

The United States District Court for the District of Oregon grants Bleauregard Kasadu leave to proceed in forma pauperis but dismisses his complaint with leave to amend. The court holds that the defendant judges are protected by absolute judicial immunity from damages claims, that most requested declaratory and injunctive relief is barred by the Rooker-Feldman doctrine, and that the plaintiff's facial constitutional challenge to Or. Rev. Stat. § 90.396(4) is inadequately supported.

Holdings

1. Judges are absolutely immune from damages liability for judicial acts performed in their official capacities, including alleged erroneous, procedurally irregular, malicious, or corrupt acts. Because Kasadu alleged only judicial acts by Judges Connell and Wu, his damages claims against them were dismissed.
2. The Rooker-Feldman doctrine bars federal district-court review of state-court judicial proceedings when the requested federal relief is inextricably intertwined with state-court decisions and would effectively reverse or invalidate those decisions.
3. Kasadu failed to state a cognizable facial constitutional challenge to the provision of Or. Rev. Stat. § 90.396(4) applying the preponderance-of-the-evidence standard in an action for possession.
4. The court may dismiss an in forma pauperis complaint before service if it is frivolous, fails to state a claim, or seeks monetary relief from an immune defendant, and a self-represented plaintiff should ordinarily be given leave to amend unless the deficiencies cannot be cured.

Questions Presented

1. Whether damages claims against Judges Connell and Wu were barred by absolute judicial immunity.
2. Whether Kasadu's declaratory and injunctive claims seeking relief that would effectively review or invalidate state-court rulings were barred by the Rooker-Feldman doctrine.
3. Whether Kasadu stated a cognizable facial constitutional challenge to the preponderance-of-the-evidence provision in Or. Rev. Stat. § 90.396(4).
4. Whether the complaint should be dismissed during in forma pauperis screening, with leave to amend.

Disposition

other