Mendez-Nouel v. Rodriguez
- Vargas
- 1:25-cv-05439
- U.S. District Court · Southern District of New York
- 4
In Mendez-Nouel v. Rodriguez, Judge Vargas dismissed with prejudice claims against Judge Katz because judicial immunity protected his judicial acts.
Adolfo Mendez-Nouel’s claims against Judge Michael L. Katz were dismissed with prejudice. The opinion does not state a disposition for the claims against the other defendants.
What happened
Adolfo Mendez-Nouel sued several defendants over an ongoing divorce and custody case in New York State Supreme Court, alleging misconduct that caused separation from his children and other harms. He represented himself and included claims against Judge Michael L. Katz.
Mendez-Nouel alleged that Judge Katz relied on sealed documents, failed to decide some motions, made threats in court, and did not follow proper procedures. He sought damages and orders preventing Judge Katz from handling future proceedings and requiring the unsealing of documents.
Judge Jeannette A. Vargas ruled that Judge Katz’s alleged actions were taken while presiding over the divorce and custody case and therefore were protected by absolute judicial immunity. She dismissed Mendez-Nouel’s claims against Judge Katz with prejudice; the opinion does not state a disposition for the claims against the other defendants.
The detailed version
- Mendez-Nouel v. Rodriguez · No. 1:25-cv-05439
- Vargas
- July 25, 2025
Background
Adolfo Mendez-Nouel filed the action while representing himself against Michelle Rodriguez, Margaret Donohoe, Paul Talbert, Lisa Gardner, John Doe, Jane Doe, and Judge Michael L. Katz. The case arose from an ongoing divorce and custody proceeding over which Judge Katz was presiding in the Supreme Court of the State of New York, County of New York.
Mendez-Nouel alleged that the defendants’ conduct caused prolonged separation from his children, career and reputational damages, denial of due process, threats to his safety, and mental-health problems. As to Judge Katz, he alleged that the judge relied on sealed and defamatory documents, failed to rule on motions and other issues, made threats in open court, communicated with friends of another defendant, and disregarded proper judicial procedure. The complaint sought injunctive relief, compensatory and punitive damages under 42 U.S.C. §§ 1983 and 1985, and damages for intentional infliction of emotional distress.
Judicial Immunity
The court considered judicial immunity on its own initiative. Judicial immunity generally protects judges from personal liability for acts taken within the scope of their judicial jurisdiction. The protection applies even when the alleged acts were erroneous, made in bad faith, or harmful. The court also explained that judges are generally protected from injunctions unless a declaratory judgment was violated or declaratory relief was unavailable.
Application
The court determined that the allegations against Judge Katz concerned his conduct while presiding over Mendez-Nouel’s divorce and custody proceedings. The alleged threat, failures to rule on subpoenas and spousal-support issues, and communications with friends of another defendant all concerned actions taken within the scope of Judge Katz’s judicial jurisdiction. The court stated that this jurisdiction must be interpreted broadly and that the allegations of error or bad faith did not overcome absolute judicial immunity.
Disposition
The court held that it was unmistakably clear that Judge Katz was protected by absolute judicial immunity. It dismissed Mendez-Nouel’s claims against Judge Katz with prejudice. The opinion does not state that the claims against the other defendants were resolved.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.