Mazgaj v. Charles

Summary

The United States District Court for the Southern District of California granted Jason Charles’s motion to dismiss a pro se complaint brought by Mildred Mazgaj and Marian Anthony. The court held that the plaintiffs lacked standing to pursue criminal claims and claims arising from Charles’s testimony in state family-court proceedings, and that Charles was protected by absolute witness immunity. The complaint was dismissed with prejudice.

Holdings

1. Private citizens lack a judicially cognizable interest in the prosecution or nonprosecution of another and therefore lack standing to assert claims based solely on the criminal statutes identified in the complaint.
2. Plaintiffs lacked standing to pursue claims arising from Jason Charles's involvement as a witness in the state-court dissolution and child-custody proceedings because witnesses are absolutely immune from lawsuits based on their testimony.
3. The complaint was properly dismissed with prejudice because Plaintiffs' claims against Charles were barred by absolute witness immunity and it was plainly unlikely that Plaintiffs could cure the standing defect.

Questions Presented

1. Whether Plaintiffs had Article III standing to assert claims based on criminal statutes against a private individual.
2. Whether Plaintiffs had standing to sue Jason Charles for claims arising from his testimony as a witness in judicial proceedings.
3. Whether dismissal for lack of subject-matter jurisdiction should be with prejudice where the claims are barred by absolute witness immunity and the standing defect is plainly incurable.

Disposition

dismissed