Murray v. Murguia

Background

Sara Murray filed this civil action and an application to proceed without paying filing fees. She later moved for a preliminary injunction. The complaint asserted claims under Title II of the Americans with Disabilities Act (ADA) and Section 504 of the Rehabilitation Act of 1973 against Chief Judge Mary Murguia and the United States Court of Appeals for the Ninth Circuit.

Murray alleged that she had post-traumatic stress disorder-related brain injuries and cognitive impairments that prevented her from representing herself in legal proceedings without significant medical harm. She said that, on October 15, 2024, she submitted a judicial complaint concerning a federal judge in the Western District of Washington and requested appointment of counsel as an ADA accommodation. According to the complaint, the defendants did not provide that accommodation in January 2025, which deprived her of the ability to fully participate in the judicial-complaint process.

Court’s analysis

The court reviewed the complaint under 28 U.S.C. § 1915, which requires dismissal of a case filed without paying fees if, among other things, it is frivolous, fails to state a claim, or seeks money from an immune defendant. The court concluded that Murray failed to state a claim.

First, the court held that judicial immunity barred the claims. Judicial immunity generally protects judges from civil liability for actions taken in their judicial capacities, including actions alleged to be erroneous, malicious, or beyond the judge’s authority, unless the judge acted in the clear absence of all jurisdiction. The court characterized Murray’s claims as challenges to Chief Judge Murguia’s and the Ninth Circuit’s ruling denying Murray’s request for appointment of counsel and concluded that the ruling was made as part of judicial actions.

Second, the court stated that Title II of the ADA applies to public entities defined in the statute as state or local governments and related entities, not the federal government. It also stated that Section 504 of the Rehabilitation Act applies to specified federally funded programs and executive-branch programs, not the federal judiciary.

Finally, the court said the complaint was effectively an appeal of the Ninth Circuit’s decision not to appoint counsel. Granting the requested relief would require a district court to overturn an appellate court’s decision, and the court stated that it knew of no authority permitting that relief.

Action taken and recommendation

The court granted Murray’s application to proceed without paying filing fees. It reassigned the action to a district judge and recommended that the case be dismissed with prejudice because Murray could not state a legally cognizable claim. It also recommended that her motion for appointment of counsel and motion for a preliminary injunction be denied as moot.

The order stated that a party could file objections with the district judge within 14 days after being served. It warned that failing to object within that period might waive the right to appeal the district court’s order. The text identifies the signer as a United States Magistrate Judge, but the supplied case metadata identifies Judge William Orrick; the signer’s full name is not legible in the provided opinion text.