Raymond Hill v. Judge Marc J. Lieberman, et al.

Summary

The Eastern District of Pennsylvania granted Raymond Hill leave to proceed in forma pauperis, dismissed with prejudice his claims against the magisterial district judge, public defender, police department, and Commonwealth of Pennsylvania, and dismissed his requests for release and termination of defendants’ employment. The court stayed Hill’s remaining damages claims concerning alleged false arrest, false imprisonment, and malicious prosecution under Younger abstention principles because his state criminal proceedings were ongoing. The court also denied without prejudice Hill’s request to add Chester County Prison and its warden as defendants.

Holdings

1. A claim challenging the fact or duration of imprisonment and seeking immediate or speedier release must be pursued through habeas corpus, not a § 1983 civil-rights action.
2. The court lacks authority in this § 1983 action to order the termination of state employees from their employment.
3. A judge is absolutely immune from civil-rights damages claims for judicial acts performed within jurisdiction, even when the acts are alleged to be legally incorrect, malicious, corrupt, or procedurally flawed.
4. A public defender does not act under color of state law when performing traditional functions as counsel to a criminal defendant and therefore is not liable under § 1983 on that basis.
5. A municipal police department, as a subunit of the municipality, is not a proper defendant under § 1983.
6. The Commonwealth of Pennsylvania is not a person subject to damages liability under § 1983 and is immune from suit for damages in federal court under the Eleventh Amendment absent consent or waiver.
7. The remaining claims concerning false arrest, false imprisonment, and malicious prosecution should be stayed because they relate to ongoing state criminal proceedings in which Hill may raise his constitutional challenges.

Questions Presented

1. Whether Hill's requests for release from custody based on alleged constitutional violations are cognizable in a § 1983 action.
2. Whether the court could order the termination of police officers' and a judge's employment as relief in this § 1983 action.
3. Whether the magisterial district judge was entitled to absolute judicial immunity for setting bail.
4. Whether Hill's appointed public defender acted under color of state law for purposes of § 1983.
5. Whether the West Chester Police Department is a proper defendant under § 1983.
6. Whether the Commonwealth of Pennsylvania is a person subject to suit for damages under § 1983 and whether it is protected by Eleventh Amendment immunity.
7. Whether Hill's remaining Fourth Amendment claims should be stayed under Younger abstention because related state criminal proceedings were ongoing.

Disposition

other