Jr. v. Judge Laura Taylor Swain
- Kimba Wood
- 1:25-cv-08815
- U.S. District Court · Southern District of New York
- 5
In Rafferty v. Swain, Judge Wood dismissed Rafferty’s damages case because judicial immunity barred claims tied to Swain’s judicial work.
James L. Rafferty Jr.’s case was dismissed, and he was denied permission to amend and fee-free status for an appeal. Judge Laura Taylor Swain was protected from the damages claims by judicial immunity.
What happened
In James L. Rafferty Jr. v. Judge Laura Taylor Swain, James L. Rafferty Jr. sued Judge Laura Taylor Swain over proceedings he said she handled in 2019. He alleged that people who had tried to take his life were found guilty and that he was awarded $235,000, but he had not received the money. He sought $100 million in damages and said the delay caused financial hardship.
The court explained that judges generally cannot be sued for damages based on actions taken as part of their judicial responsibilities. Rafferty did not allege facts showing that Judge Swain acted outside her judicial role or jurisdiction. The court therefore dismissed the complaint under the rules governing fee-free lawsuits, including because it sought money from an immune defendant and did not state a claim for relief.
Judge Kimba M. Wood also denied Rafferty permission to amend because an amendment could not fix the defects. The court denied fee-free status for any appeal, certified that an appeal would not be taken in good faith, and directed the Clerk of Court to enter judgment dismissing the case.
The detailed version
- Jr. v. Judge Laura Taylor Swain · No. 1:25-cv-08815
- Kimba Wood
- Nov. 5, 2025
Background
James L. Rafferty Jr. filed the action without a lawyer against Judge Laura Taylor Swain. The court had previously allowed him to proceed without prepaying filing fees. Rafferty alleged that events connected to his claims occurred at 500 Pearl Street in New York. He stated that in 2019 a judge found a large group of people guilty of trying to take his life, that the people faced possible jail time, and that he was awarded $235,000 under an agreement providing that payment would take about five years. He alleged that the payment had not been resolved after that period, causing financial hardship, including reliance on food pantries and Social Security Disability benefits. He claimed constitutional violations and requested $100 million in damages.
The opinion states that the legal matter Rafferty was referring to was unclear. He referred to state-court proceedings, but he did not identify those proceedings. The court also noted that some of his remarks appeared to be directed at Judge Swain and could be viewed as threatening.
Judicial Immunity
When a person proceeds without prepaying filing fees, the court must dismiss the complaint if it is frivolous, fails to state a claim for relief, or seeks money from a defendant who is immune from that relief. The court must also dismiss a case over which it lacks subject-matter jurisdiction. Although courts read filings by people without lawyers liberally, those filings must still provide enough facts to state a plausible claim.
The court held that absolute judicial immunity protected Judge Swain from Rafferty’s damages claims. Judges are immune from damages suits for actions taken within their judicial responsibilities, including actions arising from or related to cases before them. The court concluded that Rafferty’s claims arose from proceedings that he alleged Judge Swain had presided over in 2019. Rafferty did not allege facts showing that Judge Swain acted outside her judicial capacity or jurisdiction. The court therefore dismissed the claims because they sought monetary relief from an immune defendant and were frivolous under the fee-free filing statute.
Other Rulings and Disposition
The court denied Rafferty leave to amend the complaint because an amendment could not cure its defects. The complaint was dismissed under the doctrine of judicial immunity, as frivolous, for failure to state a claim for relief, and for seeking monetary relief from a defendant immune from that relief.
The court certified that any appeal would not be taken in good faith and denied fee-free status for purposes of an appeal. It directed the Clerk of Court to enter judgment dismissing the case.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.