Austin v. Chesney

Background

George Jarvis Austin, a self-represented plaintiff, sued United States District Judge Maxine M. Chesney. An earlier order dismissed the action with prejudice. Austin then moved for reconsideration.

Reasons for the Decision

The court explained that reconsideration is an extraordinary remedy used sparingly. It generally requires newly discovered evidence, a clear error in the earlier decision, or an intervening change in controlling law. The court found that Austin offered none of those grounds. Austin also conceded that the earlier order appeared partially correct in concluding that Judge Chesney was protected from civil liability.

Austin argued that judicial immunity did not prevent equitable relief, including prospective declaratory relief. The court rejected that argument. It distinguished a prior case involving a claim against state court clerks and staff, explaining that Austin sought relief against a federal judge. The court stated that federal judges are absolutely immune from civil liability for acts performed in their judicial capacity, and that this protection extends beyond damages to declaratory, injunctive, and other equitable relief.

The court found that Austin provided no evidence or allegations showing that Judge Chesney acted without any jurisdiction or acted outside a judicial role. It also rejected Austin’s argument that judicial immunity does not cover administrative acts, concluding that Judge Chesney was acting squarely within her judicial capacity when she ruled against Austin in the underlying case.

Disposition

Judge William Alsup denied Austin’s motion for reconsideration and vacated the hearing. The order stated that Austin could continue pursuing his appeal of the earlier dismissal in the court of appeals, but that the matter was over in the district court unless the court of appeals took further action.