Cooper v. John Doe County Court Clerk

Background

Kaazim Cooper, also identified as Kazzim Cooper, filed the action under 42 U.S.C. § 1983, a federal civil-rights statute. He was proceeding without a lawyer and had been granted permission to file without paying the filing fee in advance.

Cooper sued New York Supreme Court Judges Abraham Clott and Jennifer G. Schecter and a John Doe county court clerk. According to the complaint, Cooper was arrested on criminal-assault and parole-violation charges in 2021 and remained detained on Rikers Island after his parole term ended. He filed a state habeas petition in February 2022. The state appellate court transferred the petition to the New York Supreme Court.

Cooper alleged that the version of the petition returned to him was incomplete, with every odd-numbered page and some exhibits missing. He asserted that the clerk deliberately omitted the pages, that Judge Schecter directed the clerk to place the petition on the calendar and assign it an index number, and that Judge Clott later denied the petition after a hearing. Cooper sought money damages, declaratory relief, and injunctive relief. He alleged violations involving access to courts, the right to petition, habeas rights, equal protection, and a nondiscrimination provision of the New York Constitution.

Legal standards

Because Cooper was allowed to proceed without prepaying fees, the court was required to dismiss the complaint, or any part of it, if it was frivolous, failed to state a claim for relief, or sought money damages from an immune defendant. The court also had to dismiss claims over which it lacked subject-matter jurisdiction. Although courts read self-represented pleadings generously, the complaint still had to provide enough factual detail to make a legally plausible claim.

Claims against Judges Clott and Schecter

The court held that judges are absolutely immune from damages claims for actions taken within their judicial responsibilities. This immunity generally covers actions arising from or related to individual cases before the judge, even when the plaintiff alleges bad faith or malicious conduct.

The court explained that judicial immunity does not apply when a judge acts outside the judicial role or in the complete absence of jurisdiction. But it found that Cooper alleged no facts showing that either judge acted outside the judicial role or jurisdiction. Transferring or accepting an incomplete habeas petition did not establish a lack of jurisdiction.

The court therefore dismissed the claims against Judges Clott and Schecter for money damages because the judges were immune, and treated those claims as frivolous under the statute governing fee-free cases. It dismissed Cooper’s claims for injunctive and declaratory relief for failure to state a claim because he did not allege that either judge violated a declaratory decree, that declaratory relief was unavailable, or that an appeal was unavailable.

Claims against the John Doe county clerk

The court applied quasi-judicial immunity, which can protect court clerks and others who perform functions closely connected to the judicial process. It held that filing and docketing court documents are integral parts of that process.

The court found that Cooper’s allegation that the clerk omitted pages while docketing the habeas petition involved a function protected by absolute quasi-judicial immunity. It also found no allegation that Cooper had been prevented from starting a state-court action; according to his complaint, he was able to file the petition and a judge rejected it after a hearing. The court dismissed the claims against the clerk under quasi-judicial immunity and for failure to state a claim for relief, including the requested injunctive and declaratory relief.

State-law claims and amendment

After dismissing the federal claims, the court declined to exercise supplemental jurisdiction, meaning authority to hear related state-law claims, over any state-law claims Cooper might have been asserting.

The court denied leave to amend. It stated that amendment would be futile because the defects in the complaint could not be cured by filing an amended complaint.

Disposition

Judge Louis L. Stanton dismissed the complaint under the doctrines of judicial and quasi-judicial immunity, for failure to state a claim, and as frivolous. The court declined supplemental jurisdiction over any state-law claims, denied leave to amend, and directed the Clerk of Court to enter judgment dismissing the action. The court expressly stated that it was not ruling that a non-personal action by Cooper in state court would necessarily fail.