Tigano v. Alameda County Superior Court

Background

Elizabeth G. Tigano and her sister, Mary Bernstein, represented themselves in this action against the Alameda County Superior Court and seven judicial defendants: Judge Eumi Lee, Judge Keith Fong, Judge Jenna Whitman, Judge Elizabeth Riles, Judge Susan Lew, Judge Bentrish Satarzadeh, and Commissioner, now Judge, Mark Fickes.

Plaintiffs had previously filed a related action alleging violations of the Americans with Disabilities Act and 42 U.S.C. § 1981. They voluntarily dismissed that action and then filed this case against many of the same defendants. The court related the two actions.

The complaint in this case asserted two claims: religious discrimination under 42 U.S.C. § 1981 and disability discrimination under 42 U.S.C. § 13132. Plaintiffs alleged that the defendants denied reasonable accommodations and discriminated against them based on their status as disabled Christian women in several state-court cases. They sought a ruling that the defendants’ decisions violated the law, reversal of those decisions, and damages.

Defendants’ Motion

The defendants moved to dismiss. They argued that the Eleventh Amendment barred the claims, that the Rooker-Feldman doctrine prevented the federal district court from reviewing state-court decisions, and that the individual judges had absolute judicial immunity. They also moved alternatively to dismiss for failure to state a claim, although the court resolved the motion on the stated immunity and jurisdictional grounds.

Court’s Analysis

The court held that the Alameda County Superior Court is an arm of the state protected by the Eleventh Amendment. It also held that claims against state judges in their judicial capacities are barred by the same immunity. The court found that Plaintiffs’ allegations concerned actions taken while the defendants presided over judicial proceedings and ruled on matters in state-court cases.

The court also held that the Rooker-Feldman doctrine barred the claims. That doctrine prevents a federal district court from functioning as an appeal court for a final state-court judgment. The court found that Plaintiffs challenged the defendants’ state-court actions and rulings and sought relief that would effectively reverse those decisions. It stated that the claimed discrimination and denial of reasonable accommodations were intertwined with the state-court rulings.

Finally, the court held that the individual judges were absolutely immune from suit for acts performed in their judicial capacities. The challenged actions—ruling on motions, denying requests for reasonable accommodations, and denying requests for continuances—were functions normally performed by judges. The court found no basis in the opinion for applying an exception to judicial immunity.

Disposition

Judge Jacqueline Scott Corley granted the defendants’ motion to dismiss. The court dismissed Plaintiffs’ claims without leave to amend because it concluded that any amendment would be futile. The order disposed of Docket Nos. 5 and 17.