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N.D. Cal.Procedural orderFiled May 6, 2022

Christ v. Trump

Judge
William Orrick
Docket
3:22-cv-02402
Court
U.S. District Court · Northern District of California
Pages
2
Civil Procedure
In one sentence

In Christ v. Trump, Judge William H. Orrick dismissed the action with prejudice because claim preclusion and immunity barred the claims.

Who this affects

Jesus Christ, also known as Michelle Yvonne Wood, whose action was dismissed with prejudice; Donald Trump, whom the opinion said was protected by presidential immunity; and Judges Chhabria and Hixson, whose alleged claims were described as barred by judicial immunity.

What happened

In Christ v. Trump, Jesus Christ, also known as Michelle Yvonne Wood, sued Donald Trump. A magistrate judge recommended dismissing the complaint without allowing an amendment.

The plaintiff objected, arguing that dismissal was unconstitutional, that she was denied the First Amendment right to speak in court, and that judges could not decide whether her claims were valid. The court found those objections insufficient.

Judge William H. Orrick adopted the recommendation in full and dismissed the action with prejudice. He concluded that the claims were based on the same alleged conduct as an earlier case, were barred by the rule against relitigating the same matter, and were also barred by presidential immunity; claims against Judges Chhabria and Hixson were barred by judicial immunity.

The detailed version

For law students, journalists, and other readers who want the full reasoning

Case
Christ v. Trump · No. 3:22-cv-02402
Judge
William Orrick
Date
May 6, 2022

Background

Jesus Christ, also known as Michelle Yvonne Wood, filed a complaint against Donald Trump. On April 20, 2022, Chief Magistrate Judge Joseph C. Spero issued a Report and Recommendation advising that the complaint be dismissed without leave to amend. The plaintiff objected on April 27, 2022.

Reasons for Dismissal

The court adopted Judge Spero’s recommendation in full. It held that the complaint was barred by res judicata, the rule that generally prevents a party from pursuing the same matter after it was resolved in an earlier case. The court said the complaint was based on the same alleged conduct as the plaintiff’s previous case against the defendant, which had been dismissed with prejudice.

The court also held that the claims against Donald Trump were barred by absolute presidential immunity from damages liability for acts within the outer perimeter of a president’s official responsibilities. The claims against Judges Chhabria and Hixson were described as barred by judicial immunity.

Objections

The plaintiff argued that dismissal was unconstitutional because it allowed judges to issue decisions without a jury’s consent, that she was denied a First Amendment right to speak in court, and that a judge could not determine whether her claims were valid. The court concluded that the first two objections overlapped with arguments made in the earlier complaint and that the remaining objections were deficient. It explained that courts are responsible for evaluating whether a complaint is legally sufficient and whether a claim may proceed.

Disposition

Judge William H. Orrick ordered: “This action is DISMISSED with prejudice.”

The authoritative version

Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.

Open opinion PDF →
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