Garrison v. U.S. Judicial Commission

Background

Self-represented plaintiff Steve Garrison filed a complaint and an application to proceed in forma pauperis, meaning without prepaying the filing fee. The court granted that application and screened the complaint under 28 U.S.C. § 1915(e)(2), which requires courts to dismiss certain complaints filed by people proceeding this way.

Garrison based his claims on the dismissal of three earlier Northern District of California cases. He alleged that those cases were dismissed without a summons being issued or served, in violation of Federal Rule of Civil Procedure 4, and that only a grand jury could dismiss a case. He requested $2.5 billion in damages and an injunction requiring service of summonses in the earlier cases.

Claims and Defendants

Garrison asserted claims under the 1964 Civil Rights Act, the Racketeer Influenced and Corrupt Organizations Act, and 22 U.S.C. § 7102. The court noted that Garrison did not identify which title of the 1964 Civil Rights Act he invoked and did not allege discrimination supporting a claim under any relevant title. The court found that Garrison did not allege an enterprise required for a Racketeer Influenced and Corrupt Organizations Act claim.

The court explained that 22 U.S.C. § 7102 defines terms used in other statutes and does not provide a private right of action. Because Garrison referred to human trafficking, the court understood him to be attempting to invoke the Trafficking Victims Protection Act. The court found that he did not allege that he was a human-trafficking victim, as required for that statute’s civil remedy.

The complaint named the “U.S. Judicial Commission,” District Judge Yvonne Gonzalez Rogers, and District Judge James Donato. The court stated that the “U.S. Judicial Commission” is not a real entity and that the complaint contained only a conclusory allegation that it was responsible for the prior dismissals. Judge Gonzalez Rogers had presided over two of the earlier cases. The complaint contained no allegations against Judge Donato, who had not presided over any case referenced in the complaint.

Reasons for Dismissal

The court identified three reasons the complaint had to be dismissed. First, it failed to allege facts plausibly supporting a claim under the 1964 Civil Rights Act, the Racketeer Influenced and Corrupt Organizations Act, or the Trafficking Victims Protection Act.

Second, the court held that, with one possible exception, the claims were untimely. It stated that the Trafficking Victims Protection Act provided the longest limitations period among the asserted claims, ten years. Claims arising from the dismissals of the earlier Brown and Davila cases were time-barred, and the Racketeer Influenced and Corrupt Organizations Act and Trafficking Victims Protection Act claims arising from the Trump case were also time-barred.

Third, the court held that judicial immunity barred the claims seeking damages and retrospective injunctive relief. Judicial immunity generally protects judges from damages liability for judicial acts, and the court treated dismissing a case as a quintessential judicial act. The court also held that judicial immunity barred the claims against the “U.S. Judicial Commission” because Garrison sought to hold that entity responsible for judicial acts by defendants who were immune.

Disposition

The court dismissed the complaint for failure to state a claim. It dismissed the complaint with prejudice and without leave to amend because amendment would be futile: the claims had legal deficiencies, some were time-barred, and the defendants were protected by absolute immunity. The court directed the clerk to close the case and unseal the record.