Thornton v. Moorman
- William Orrick
- 3:21-cv-03661
- U.S. District Court · Northern District of California
- 2
In Thornton v. Moorman, Judge Orrick dismissed Thornton’s Section 1983 suit because the judge defendant was immune, while granting leave to amend.
Simon Thornton’s federal civil-rights suit was dismissed, and judgment was entered in favor of Ann Moorman. The ruling applied judicial immunity to the state judge’s alleged trial-related conduct.
What happened
In Thornton v. Moorman, Simon Thornton alleged that Ann Moorman, the state judge who presided over his criminal trial, violated his constitutional rights by issuing a ruling during the trial.
The court screened Thornton’s federal civil-rights complaint under a law requiring review of certain prisoner claims. It concluded that state judges are protected from damages lawsuits for actions taken in their judicial roles.
Judge William H. Orrick dismissed the suit, directed the clerk to enter judgment for Moorman and close the case, and also granted Thornton’s motion for leave to file an amended complaint.
The detailed version
- Thornton v. Moorman · No. 3:21-cv-03661
- William Orrick
- Sept. 22, 2021
Background
Simon Thornton sued Ann Moorman under 42 U.S.C. § 1983, a federal civil-rights law. Thornton alleged that Moorman, the California state court judge who presided over his criminal trial in Mendocino County, issued a ruling during the trial that violated his constitutional rights.
Court’s analysis
The court reviewed the complaint under 28 U.S.C. § 1915A, which requires preliminary screening of certain prisoner lawsuits against governmental entities or officials. At screening, the court must dismiss claims that are frivolous, fail to state a claim, or seek money damages from a defendant protected from that relief. The court also noted that complaints filed without a lawyer must be read liberally.
The court held that a state judge has absolute immunity from civil damages liability for actions performed in the judge’s judicial capacity. Because Thornton’s allegations concerned Moorman’s ruling during his criminal trial, the court concluded that the action could not proceed.
Disposition
The court dismissed the federal civil-rights suit, directed the clerk to terminate pending motions, enter judgment in Moorman’s favor, and close the file. The opinion also states that Thornton’s motion for leave to file an amended complaint was granted. The text does not explain how that grant relates to the dismissal, judgment, and closure instructions.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.