Griffin v. Demartini

Background

Jeremiah Griffin, who was incarcerated at the Robert N. Davoren Center on Rikers Island, filed this action without a lawyer under 42 U.S.C. § 1983. He sued New York State Supreme Court Judges April Newbauer, Beth Beller, and Miriam Best, as well as New York County Assistant District Attorney Katherine DeMartini.

Griffin alleged that Judge Newbauer refused to consider his motion arguing that he had been denied the right to testify before the grand jury. He alleged that Judge Best denied his speedy-trial motion and that Judge Beller treated a prosecution-requested adjournment as excluded from the speedy-trial calculation. Griffin also alleged that Judge Beller denied bail. He sought, among other relief, intervention in his pending state criminal case and release from custody.

The court had previously granted Griffin permission to proceed without prepaying the filing fee. Under the prisoner-screening statutes, the court was required to dismiss claims that were frivolous, failed to state a legally sufficient claim, sought money from an immune defendant, or fell outside the court’s jurisdiction.

Claims Against the Judges

The court dismissed Griffin’s claims for damages against Judges Newbauer, Beller, and Best based on absolute judicial immunity. That doctrine generally protects judges from damages suits for acts performed within their judicial responsibilities, even when a plaintiff alleges bad faith or malice. The court found that the challenged conduct arose from the judges’ handling of Griffin’s criminal case.

The court also dismissed Griffin’s request for injunctive relief against the judges. Although judicial immunity does not categorically bar prospective injunctive or declaratory relief, Section 1983 sharply limits injunctive relief against a judicial officer. Griffin had not alleged that a declaratory decree was violated or that declaratory relief was unavailable. The court therefore dismissed these claims as frivolous and for failure to state a claim.

Claims Against the Prosecutor

The court dismissed the claims against Assistant District Attorney DeMartini under absolute prosecutorial immunity. Prosecutors are generally immune from damages claims for actions closely connected to the judicial phase of a criminal case. The court concluded that Griffin’s claims concerned actions within DeMartini’s official duties and associated with conducting a trial. It dismissed those claims because they sought monetary relief from an immune defendant and, consequently, treated them as frivolous.

Interference With the State Criminal Case

The court declined to intervene in Griffin’s pending state criminal proceedings. Under the rule from Younger v. Harris, federal courts generally must not enjoin ongoing state criminal cases unless special circumstances show bad faith, harassment, or serious and immediate irreparable injury. The court found that Griffin had alleged no facts showing those circumstances. It therefore denied his claims for declaratory and injunctive relief concerning the state proceedings.

Request for Release From Custody

The court explained that a person cannot obtain release from custody through a Section 1983 action. A petition under 28 U.S.C. § 2241, a federal procedure for challenging detention, may be the proper vehicle for a state pretrial detainee in some circumstances. But such a petitioner must first exhaust available state-court remedies. Because Griffin’s complaint did not show exhaustion of his speedy-trial challenge, the court declined to convert the Section 1983 case into a § 2241 petition.

Any custody-related claims were dismissed without prejudice to Griffin filing a § 2241 petition after exhausting his state remedies.

Leave to Amend and Disposition

The court declined to give Griffin permission to amend because it found that the defects in the complaint could not be cured by amendment. The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(i)–(iii). The order did not state that the dismissal of the Section 1983 complaint was with or without prejudice; it specifically stated that any custody-related claims could be refiled without prejudice after exhaustion.

The court also stated that a certificate of appealability would not issue because Griffin had not made a substantial showing that a constitutional right was denied. It certified that an appeal would not be taken in good faith and denied permission to appeal without prepaying fees. The clerk was directed to enter a civil judgment dismissing the case.