Spillard v. Tigar

Background

Everett Spillard, a prisoner at the California Medical Facility in Vacaville, filed a petition asking the court to issue a writ of mandamus—an order requiring a government official or court to perform a specified act. He asked the court to compel Judge Jon S. Tigar to provide notice of rulings in another case, Spillard v. Hoffman. Spillard alleged that Judge Tigar had made several errors in that case.

Screening and analysis

Because Spillard was a prisoner seeking relief from a government officer, the court screened the petition under 28 U.S.C. § 1915A. That statute requires the court to identify claims that can proceed and dismiss claims that are frivolous, malicious, fail to state a claim, or seek relief from an immune defendant.

The court held that a district court has no authority to issue a writ of mandamus to another district court. It therefore lacked jurisdiction—the legal power to decide the requested matter—and could not order Judge Tigar to do anything in a case pending before him. Treating the petition as an appeal would not help because a district court also lacks appellate authority over another district court's decisions.

The court further stated that allowing Spillard to file a civil complaint against Judge Tigar would be futile. Federal judges have absolute judicial immunity from civil liability for acts performed in their judicial capacity, including claims seeking declaratory, injunctive, or other equitable relief. The court determined that Judge Tigar's alleged acts were performed in his judicial capacity.

Disposition

Judge Edward Chen dismissed the action because the court lacked authority to issue a writ of mandamus compelling Judge Tigar to act in a case pending before him. The Clerk was directed to close the file. The court noted that challenges to Judge Tigar's decisions could be made through a motion in the case before Judge Tigar or an appeal in the Ninth Circuit, without suggesting that either method would succeed.