Matthew T. Estes v. Robert N. Mayer, et al.

Summary

The United States District Court for the Eastern District of Missouri grants Matthew Estes’s application to proceed without prepaying fees and assesses an initial partial filing fee of $22.66. The court dismisses his 42 U.S.C. § 1983 action without prejudice for failure to state a claim, concluding that official-capacity damages claims are barred by the Eleventh Amendment and that the judicial defendants are entitled to judicial immunity. The court also declines supplemental jurisdiction over any state-law claims.

Holdings

1. A suit against Jeff Benoist in his official capacity was a suit against the Missouri Commission on the Retirement, Removal and Discipline of Judges and therefore against the State of Missouri; neither a State nor a state official acting in an official capacity is a person subject to a damages action under § 1983.
2. The Eleventh Amendment barred Estes's claims for money damages against the defendants in their official capacities because the State had not waived its immunity.
3. Judges Mayer and Spielman were entitled to absolute judicial immunity from Estes's claims arising from their conduct while presiding over his criminal cases.
4. The complaint was frivolous and/or failed to state a plausible claim for relief, and dismissal without prejudice was appropriate under 28 U.S.C. § 1915(e)(2)(B).

Questions Presented

1. Whether the complaint stated a viable § 1983 claim against a state judicial-discipline commissioner sued in his official capacity.
2. Whether official-capacity claims for damages against the state defendants were barred by the Eleventh Amendment and by § 1983's person requirement.
3. Whether the claims against the state judges were barred by judicial immunity.
4. Whether the complaint was subject to dismissal under 28 U.S.C. § 1915(e)(2)(B).

Disposition

dismissed