Coffer v. Kliszewski

Background

Jonathan C. Coffer, a prisoner representing himself, filed a civil-rights lawsuit challenging his 2007 commitment to the California Youth Authority. He alleged that Judge Kliszewski of the Alameda County Superior Court sentenced him to eight years in the California Youth Authority and that Assistant District Attorney Maryann Migas deliberately sent him there while knowing the commitment was illegal. Coffer also alleged that learning about the alleged illegal commitment caused him to stop eating and cut his wrists. He sought money damages from both defendants.

The court had previously dismissed Coffer’s complaint while allowing him to amend it. After Coffer filed two amended complaints and a letter requesting further leave to amend, the court screened the second amended complaint under 28 U.S.C. § 1915A. That screening law requires courts to dismiss claims by prisoners seeking relief from governmental entities or officials when the claims are frivolous, fail to state a claim, or seek money from an immune defendant.

Claims Against Judge Kliszewski

The court applied absolute judicial immunity, which generally protects judges from civil damages claims for acts performed in their judicial capacity. It concluded that sentencing Coffer during juvenile proceedings was unquestionably a judicial act performed in that capacity. The court rejected Coffer’s reliance on a California case because, as described by the court, that case did not address judicial immunity or civil-rights claims based on judicial acts.

The court held that Coffer failed to state a claim for relief against Judge Kliszewski. Because Coffer had not shown that he could correct the problem through another amendment, the claims against Kliszewski were dismissed without leave to amend.

Claims Against Migas

The court applied absolute prosecutorial immunity, which protects prosecutors from damages claims for actions taken as advocates for the government and closely connected to the judicial phase of a criminal case. The court determined that advocating for a particular disposition during juvenile delinquency proceedings was closely connected to that judicial process.

The court therefore concluded that Migas was absolutely immune from Coffer’s claim. Because Coffer had not shown that he could amend the claim to overcome prosecutorial immunity, the claim against Migas was dismissed without leave to amend.

Disposition

Judge Sumi K. Lee denied Coffer’s request for leave to amend. The court dismissed the action with prejudice for failure to state a claim and directed the clerk to enter judgment and close the file.