Jonathan C. Coffer v. Judge Kliszewski, et al.

Summary

The United States District Court for the Northern District of California screened Jonathan Coffer’s second amended 42 U.S.C. § 1983 complaint concerning his 2007 commitment to the California Youth Authority. The court held that the defendant judge was entitled to absolute judicial immunity and the defendant prosecutor was entitled to absolute prosecutorial immunity. The court denied leave to amend and dismissed the action with prejudice for failure to state a claim.

Holdings

1. A state judge is absolutely immune from liability for damages under 42 U.S.C. § 1983 for acts performed in a judicial capacity, and sentencing Coffer during juvenile proceedings was a judicial act. The claims against Judge Kliszewski therefore failed to state a claim and were dismissed without leave to amend.
2. A prosecutor is absolutely immune from liability for conduct undertaken as an advocate for the State and intimately associated with the judicial phase of a criminal or juvenile delinquency proceeding. Advocating for a specific disposition in juvenile proceedings falls within that protected function, so the claims against Migas were dismissed without leave to amend.
3. The action was dismissed with prejudice for failure to state a claim, and further leave to amend was denied because the defects caused by judicial and prosecutorial immunity could not be cured by amendment.

Questions Presented

1. Whether the claims for damages against Judge Kliszewski were barred by absolute judicial immunity.
2. Whether the claims for damages against Assistant District Attorney Migas were barred by absolute prosecutorial immunity.
3. Whether Coffer should receive further leave to amend after the court previously granted leave to amend.

Disposition

dismissed