Austin v. Chesney

Background

George Jarvis Austin, proceeding without a lawyer, sued United States District Judge Maxine M. Chesney for allegedly violating his constitutional rights by ruling against him in a separate, ongoing case. Austin challenged the reassignment of that case after he had consented to a magistrate judge, arguing that the reassignment meant Judge Chesney was acting without jurisdiction.

Magistrate Judge Laurel Beeler’s screening order and report and recommendation concluded that Austin failed to state a claim because Judge Chesney had judicial immunity. Austin timely objected and argued that Judge Chesney’s conduct fell within an exception to that immunity.

Court’s analysis

The court explained that judges generally have immunity from civil liability for acts performed in their judicial capacity. The two relevant exceptions are acts not taken in a judicial capacity and acts taken in the complete absence of all jurisdiction.

The court rejected Austin’s jurisdictional argument. It held that Judge Chesney had jurisdiction over the properly reassigned action because consent from all named parties was required for a magistrate judge to exercise jurisdiction, and Lyft had not consented. The court therefore concluded that judicial immunity was not overcome by the jurisdictional exception.

Disposition

Judge Alsup overruled Austin’s objection and adopted Judge Beeler’s report and recommendation in full. The court dismissed the action with prejudice and without leave to amend because no amendment could change the fact that Austin’s claims were asserted against a judicially immune defendant. The clerk was directed to close the file.