Quansah v. Justice Department

Background

Kenneth B. Quansah brought this civil-rights action without a lawyer against employees of the U.S. District Court for the Northern District of California and the U.S. Court of Appeals for the Ninth Circuit. The complaint also named the Justice Department. The employees named in the complaint were Molly C. Dwyer, Cyntharee K. Powells, Monica Fernandez, Richard W. Wieking, Elizabeth Garcia, and Cynthia Hernandez.

Quansah based his claims on actions taken in an earlier district-court case and the resulting Ninth Circuit appeal. His only factual allegation against the employees was that they had “issued orders and judgments.” He alleged claims under 42 U.S.C. §§ 1983 and 1985, the Fourteenth Amendment’s Due Process and Equal Protection Clauses, negligence, and intentional infliction of emotional distress. He sought millions of dollars in damages from each defendant.

The court had granted the United States permission to participate as an outside party because of its independent interest in the litigation. The United States filed a brief supporting dismissal. It argued that the defendants had not been properly served and asked for dismissal with prejudice and without leave to amend. Quansah filed no opposition or response.

Reasons for dismissal

The court identified three independent grounds for dismissal.

First, it held that the federal court personnel had absolute quasi-judicial immunity. This is protection from damages lawsuits for conduct closely connected to the judicial process. Because issuing orders and judgments is an integral part of that process, the court concluded that the defendants were immune from Quansah’s claims.

Second, the court held that the claims were barred by the statute of limitations. Applying California’s two-year limitations period for the types of claims alleged, the court determined that no orders or judgments had been issued in the earlier district-court case or appeal after August 2014. Because more than two years had passed before this action was filed, the claims were time-barred.

Third, the court held that the complaint did not state a plausible claim for relief. A plausible complaint must include enough factual matter for the court to reasonably infer that a defendant is liable for misconduct. The court found that merely alleging that the defendants issued orders and judgments did not identify misconduct or support liability under any theory.

The court also noted that 42 U.S.C. § 1983 does not apply to federal actors. It explained that the Supreme Court has recognized a damages action in some circumstances against federal officers for constitutional violations, but the court did not find a viable claim here.

Disposition

The court dismissed Quansah’s claims against the defendants without leave to amend because amendment would be futile in light of their immunity. It directed the Clerk to mail Quansah a copy of the order and close the file. The court vacated the scheduled hearing and decided the matter without oral argument. Judge Beth Labson Freeman signed the order on March 26, 2020.