Best v. Honorable Debra James

Background

Motisla Best, appearing without a lawyer, brought the action under federal-question jurisdiction and alleged that federally protected rights were violated during state-court proceedings. Best sued Judge Debra James, who sits in the New York State Supreme Court, New York County, and Natasha Godby, an attorney in the “Office of Legal Affairs.” Best sought money damages.

The allegations concerned a state-court action under Index Number 100935/20. Best alleged that a crime occurred on property connected to the opposing side’s counsel or employee, that Godby showed “deliberate indifference” and caused “interference,” and that Judge James caused a delay or interruption. The materials attached to the complaint included part of a brief seeking dismissal of the state case for lack of subject-matter jurisdiction, part of Judge James’s July 23, 2021 order dismissing that case for lack of subject-matter jurisdiction, and a January 23, 2025 letter concerning a complaint Best filed against Godby.

Best had also brought an earlier related proceeding involving Godby and the same underlying state-court matter, No. 23-CV-9042 (S.D.N.Y.). That proceeding was dismissed for failure to state a claim and under the rule that federal district courts generally cannot review state-court judgments. The appeal was dismissed as frivolous.

Screening standard

Because Best was allowed to proceed without prepaying fees, the court was required to dismiss the complaint, or any part of it, if it was frivolous, malicious, failed to state a claim, sought money from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also explained that it had to read a self-represented litigant’s allegations liberally, but the complaint still had to provide enough factual detail to make a legally valid claim plausible.

Claims against Judge James

The court held that judges have absolute immunity from damages claims for actions taken within the scope of their judicial responsibilities. Acts arising from or related to individual cases before a judge generally qualify as judicial acts, and allegations of bad faith or malice do not remove that protection.

The court found that Best alleged no facts showing that Judge James acted outside her judicial responsibilities or outside her jurisdiction. It also found no facts showing that Best sought a genuinely prospective remedy, that a declaratory decree had been violated, that declaratory relief was unavailable, or that an appeal was unavailable. The court therefore dismissed the claims against Judge James because they sought money from an immune defendant and, consequently, were frivolous under the fee-waiver screening statute.

Claims against Natasha Godby

The court held that government attorneys have absolute immunity for conduct connected to their work as advocates in litigation or potential litigation. It found that Best’s claims against Godby were based on actions within the scope of Godby’s official duties and associated with Best’s state-court matter. The court therefore dismissed the claims against Godby because they sought money from a defendant immune from suit.

State-court judgment and federal jurisdiction

The court separately applied the Rooker-Feldman doctrine, a jurisdictional rule that prevents a federal district court from acting as an appeals court over a state-court judgment. The rule applies when a state-court loser complains of injuries caused by the state judgment, asks the federal district court to review and reject that judgment, and filed the federal case after the state judgment was entered.

The court said that, to the extent Best challenged the final state-court judgment and sought an order vacating it, the claim was barred because the federal court could not review or cancel the state-court decision.

Leave to amend and additional warning

The court denied Best permission to amend the complaint because it concluded that the defects could not be cured by amendment. The court also noted Best’s prior related lawsuit and other complaints that had been dismissed for frivolousness, failure to state a claim, or lack of subject-matter jurisdiction.

The court warned that further duplicative or meritless litigation could result in an order barring Best from filing new actions without prepaying fees unless Best first obtained permission.

Disposition

The court dismissed the complaint under the federal statute governing screening of complaints filed without prepaying fees. It denied fee-free status for an appeal after certifying that an appeal would not be taken in good faith, and directed the clerk to enter judgment. The opinion does not state that the dismissal was with or without prejudice.