Sternberg v. Hendrickson

Background

Michael C. Sternberg proceeded without a lawyer on behalf of himself and his two children, E.W. and N.W. He brought claims alleging various violations of federal law during child-custody proceedings in California and Nevada. The defendants relevant to this order were California judicial officials and Rebecca J. Fleming, the Court Executive Officer of the Superior Court of California, County of Santa Clara. They were referred to together as the Judicial Defendants.

Arguments and analysis

The Judicial Defendants moved to dismiss the complaint on several grounds, including lack of subject-matter jurisdiction based on the Eleventh Amendment. The court described Eleventh Amendment immunity as a threshold jurisdictional bar and relied on Ninth Circuit authority stating that federal courts cannot resolve claims against state courts or state-court judges acting in a judicial capacity.

Sternberg argued that he was not seeking injunctions against the judicial officials in their judicial capacities. He said he was seeking injunctions against Chief Justice Patricia Guerrero and Presiding Judge Julie A. Emede in administrative capacities, and against Fleming, including an order requiring them to stop violating his constitutional rights, stop enforcing allegedly unconstitutional policies, rules, and laws, and remove his name from the vexatious-litigant list.

The court rejected that effort to characterize the conduct as administrative. It held that the acts alleged in the complaint arose from ongoing family-law proceedings and were judicial acts. The court therefore concluded that the defendants were also protected by absolute judicial immunity, which generally prevents damages claims based on acts performed in a judge’s judicial role. The court further held that the Section 1983 claims were not legally viable because states and state officials sued in their official capacities are not treated as "persons" subject to suit under that statute.

Ruling

The court granted the Judicial Defendants’ motion to dismiss. It ordered dismissal without leave to amend, concluding that the Eleventh Amendment, absolute judicial immunity, and Section 1983’s limits barred the plaintiffs’ claims and that further amendment would be futile. The court did not reach the defendants’ remaining grounds for dismissal.

Effect of the order

The order ended the claims against the Judicial Defendants in this case without allowing Sternberg to amend those claims. The opinion does not state the disposition of any claims against other defendants, if any.