Felgemacher v. Carney

Summary

The United States District Court for the Western District of New York denied Keith Felgemacher’s motion for reconsideration of the dismissal of his 42 U.S.C. § 1983 claims arising from custody proceedings. The court reaffirmed that judicial immunity applied to the claims against the family court judge and referee, that Ex parte Young did not support the requested injunctive relief, and that the prior dismissal would not be revisited.

Holdings

1. A motion for reconsideration must be denied absent an intervening change in controlling law, newly available evidence, or a need to correct clear error or prevent manifest injustice; Felgemacher identified no such basis.
2. Judicial immunity barred the damages claims against Carney and Castiglione because controlling proceedings in individual cases and handling records relating to cases over which they presided were judicial acts, not administrative acts.
3. The Ex parte Young exception did not preserve Felgemacher's claims for injunctive relief against the Unified Court System, Carney, or Castiglione.
4. The district court retained jurisdiction to decide the reconsideration motion because the timely motion to alter or amend judgment preceded the effectiveness of the notice of appeal.

Questions Presented

1. Whether Felgemacher demonstrated grounds warranting reconsideration of the prior dismissal under the strict standard applicable to motions for reconsideration.
2. Whether the alleged exclusion from virtual court proceedings and provision of incomplete transcripts constituted nonjudicial administrative acts outside judicial immunity.
3. Whether the Ex parte Young exception permitted Felgemacher's claims for prospective injunctive relief against the state-court judge and referee or against the New York State Unified Court System.
4. Whether the timely reconsideration motion preserved the district court's jurisdiction despite Felgemacher's subsequent notice of appeal.

Disposition

other