John W. Miller v. Andrea R. Wood, et al.

Summary

The United States District Court for the Eastern District of Michigan granted six federal judges’ motion to dismiss John W. Miller’s complaint. The court held that the defendants were entitled to absolute judicial immunity because the challenged conduct involved judicial acts, dismissed the complaint with prejudice, and denied the remaining motions as moot.

Holdings

1. Absolute judicial immunity barred Miller's claims because the challenged acts—denial of motions, dismissal of cases, and management of dockets—were judicial acts, and the complaint alleged neither that the acts were nonjudicial nor that they were performed in the absence of jurisdiction.
2. The court treated the judicial-immunity defense as arising under Rule 12(b)(6), rather than Rule 12(b)(1), because the Sixth Circuit directs courts to consider the availability of absolute judicial immunity in the Rule 12(b)(6) context.

Questions Presented

1. Whether the defendants' judicial-immunity defense should be analyzed under Rule 12(b)(6) rather than Rule 12(b)(1).
2. Whether absolute judicial immunity barred Miller's claims against the federal judges.
3. Whether Miller's motions to amend the case caption and the defendants' motion to stay should be denied as moot after dismissal.

Disposition

dismissed