Antonio Lee O’Bannon v. Dr. Eric Lesch, et al.

Summary

The United States District Court for the Western District of Kentucky dismissed Antonio Lee O’Bannon’s pro se 42 U.S.C. § 1983 action on initial review under 28 U.S.C. § 1915A. The court held that the psychiatrist was absolutely immune from damages claims based on competency evaluations and testimony, the public defenders were not state actors, and the claims against finance officials lacked allegations of personal involvement. The court also held that the requested relief concerning the return of property was barred by the Rooker-Feldman doctrine.

Holdings

1. A court-appointed psychiatrist who performs competency evaluations and testifies about those evaluations is absolutely immune from § 1983 claims for damages based on that testimony and those judicially connected functions.
2. Allegedly mean or inconsiderate statements do not, without more, rise to the level of a constitutional violation, and injunctive relief concerning future evaluations or testimony was unavailable where the plaintiff had been released from the facility and the criminal case was proceeding.
3. A public defender does not act under color of state law when performing traditional functions as counsel to a criminal defendant; therefore, claims arising from such representation do not state a § 1983 claim.
4. Section 1983 liability cannot be imposed on supervisory officials based solely on their positions or respondeat superior; a plaintiff must allege each defendant’s personal involvement or active unconstitutional conduct.
5. The federal district court lacked jurisdiction under the Rooker-Feldman doctrine to grant relief that would undo or invalidate the state-court judgment and property sale.

Questions Presented

1. Whether the claims against the court-appointed psychiatrist were barred by absolute witness and quasi-judicial immunity or failed to allege a constitutional violation.
2. Whether the claims against the public defenders stated a claim under § 1983 when they were performing traditional defense-counsel functions.
3. Whether claims against the current and former cabinet secretaries stated a § 1983 claim absent allegations of personal involvement or active unconstitutional conduct.
4. Whether the requested return of property and relief from the state-court judgment were barred by the Rooker-Feldman doctrine.
5. Whether the complaint and amended complaint should be dismissed under the mandatory screening requirements of 28 U.S.C. § 1915A.

Disposition

dismissed