Jones v. Board of Parole

Background

Monroe Jones brought a civil-rights action under 42 U.S.C. § 1983 against California’s Division of Parole Operations and Parole Agent Supervisor Virgil Jorge. He alleged that requiring him to wear an ankle monitor as a condition of parole violated his constitutional rights. Jones contended that the condition was not warranted by his recent offense and was instead related to a prior offense.

Screening and Immunity

Because Jones was a prisoner seeking relief from government defendants, the court screened the complaint under 28 U.S.C. § 1915A. The court explained that parole officials have absolute, or quasi-judicial, immunity for imposing parole conditions because that function is closely connected to decisions to grant or revoke parole. The immunity applies even when the condition is allegedly unconstitutional or officials made serious mistakes.

The court also held that the claims against the Board itself had to be dismissed because state agencies are immune from suit in federal court under the Eleventh Amendment.

Ruling

The court dismissed the complaint. It did not reach the merits of whether the ankle-monitor condition violated Jones’s constitutional rights. The court granted Jones’s application to proceed without paying filing fees, directed the Clerk to terminate pending motions, enter judgment for the defendants, and close the file. Judge William Orrick issued the order.