Seifert v. Pritchard

Summary

The United States District Court for the Eastern District of California vacates its prior findings and recommendations and issues new findings and recommendations concerning Alexandra Seifert’s civil rights complaint against Kern County Superior Court judges, a commissioner, and a court clerk. The document recommends dismissal without leave to amend based on the Rooker-Feldman doctrine, Eleventh Amendment immunity, judicial immunity, and quasi-judicial immunity. It also recommends denial of related motions and closure of the action, subject to a 21-day objection period.

Holdings

1. The cited federal criminal statutes do not provide Plaintiff with a private civil cause of action in this § 1983 proceeding.
2. The complaint's claims are barred to the extent they challenge, seek to undo, or request federal relief from the decisions and procedures of the state small-claims courts.
3. The state court judges, commissioner, and clerk are immune from Plaintiff's federal claims based on the Eleventh Amendment and, independently, judicial or quasi-judicial immunity.
4. Leave to amend should be denied because the defects in Plaintiff's claims cannot be cured by alleging additional facts.

Questions Presented

1. Whether the complaint stated a civil claim based on the cited federal criminal statutes.
2. Whether the claims seeking relief from or review of state small-claims judgments were barred by the Rooker-Feldman doctrine.
3. Whether the state court judges, commissioner, and clerk were immune from suit under the Eleventh Amendment, judicial immunity, or quasi-judicial immunity.
4. Whether amendment would be futile and therefore should be denied.

Disposition

other