Savitt v. Samuels

Background

Richard P. Savitt, appearing without a lawyer, brought a civil-rights action under 42 U.S.C. § 1983 against Judge Debra Rose Samuels of the Civil Court of the City of New York, New York County, and Judge Carol Sharpe of the New York State Supreme Court, New York County. The court had previously allowed Savitt to proceed without paying filing fees in advance.

According to the complaint, a store sold Savitt an iPhone that he was told was new but that he later concluded was refurbished. After the store refused his refund demand, Savitt filed a state-court lawsuit in 2011. He alleged that, during the state-court proceedings, Judges Samuels and Sharpe made false statements about the timing of a credit, the phone’s condition, a grievance, and scheduled hearings. He also alleged that the judges held improper private proceedings, dismissed his case when he failed to attend proceedings that he said never occurred, and imposed sanctions or possibly attorney’s fees. He sought $10 million and an order vacating all orders issued by the two judges in matters involving him.

Claims for damages

The court held that judges are absolutely immune from lawsuits seeking damages for actions taken within the scope of their judicial responsibilities. It found that Savitt’s allegations concerned actions arising from, or related to, cases over which the defendants presided. The court also found no allegations showing that either judge acted outside her judicial capacity or outside her jurisdiction. It therefore dismissed the claims for money damages because they sought monetary relief from defendants immune from that relief and, consequently, treated those claims as frivolous under the federal filing-screening statute.

Request to review state-court orders

Savitt asked the federal district court to vacate the state-court judges’ orders. The court explained that federal district courts cannot function as appellate courts reviewing state-court decisions. To the extent Savitt challenged final state-court judgments, the court said the Rooker-Feldman doctrine barred the claims. That doctrine generally prevents a federal district court from reviewing and rejecting a state-court judgment. The court stated that this conclusion assumed a judgment had been entered and that no state-court appeal remained pending. On that basis, it dismissed the claims for lack of subject-matter jurisdiction.

Request for injunctive relief

The court separately dismissed Savitt’s request for injunctive relief. Although judicial immunity does not by itself bar prospective injunctive or declaratory relief, Section 1983 limits injunctive relief against a judicial officer for acts taken in a judicial capacity unless a declaratory decree was violated or declaratory relief was unavailable. The court found that Savitt alleged neither circumstance. It therefore dismissed the request for injunctive relief for failure to state a claim.

State-law claims and amendment

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction over any state-law claims Savitt might be asserting. The court also denied leave to amend because it determined that the defects in the complaint could not be cured by amendment.

Disposition

The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B) and for lack of subject-matter jurisdiction under Federal Rule of Civil Procedure 12(h)(3). It declined supplemental jurisdiction over any state-law claims, directed the clerk to enter judgment, and entered the order on May 21, 2025.