Summary
The United States District Court for the Western District of New York grants Zakkiyya Carter leave to proceed in forma pauperis and screens her claims under 42 U.S.C. § 1983, the ADA, and the Fourteenth Amendment. The court dismisses the complaint against New York State Supreme Court Justice Gerald Greenan III based on absolute judicial immunity, concluding that the challenged conduct occurred in his judicial capacity and within his jurisdiction. The dismissal is with leave to amend by June 25, 2026.
Court
United States District Court for the Western District of New York
Jurisdiction
United States District Court for the Western District of New York
Decision date
May 12, 2026
Docket number
24-CV-1168 (JLS) (MJR)
Disposition
dismissed
Questions Presented
- Whether Carter's complaint stated a viable claim under 42 U.S.C. § 1983 or the ADA against a state judge based on alleged bias, refusal to recuse, denial of disability accommodations, and allegedly unconstitutional judicial rulings.
- Whether absolute judicial immunity barred Carter's claims against Judge Greenan.
- Whether Carter was entitled to leave to amend after dismissal at the IFP screening stage.
Holdings
- Absolute judicial immunity bars claims against Judge Greenan because the alleged refusal to recuse, denial of accommodations, and allegedly biased rulings were acts undertaken in his judicial capacity and were not alleged to have occurred in the complete absence of jurisdiction.
- Section 1983 bars claims for injunctive relief against a judicial officer unless a declaratory decree was violated or declaratory relief was unavailable; Carter alleged neither exception.
- Carter was granted leave to amend because the court did not conclude that amendment would necessarily be futile, although any amended complaint must comply with Rules 8 and 10 and contain allegations capable of overcoming the identified immunity defect.
Court Document
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