Broadnax

Background

Broadnax, identified as a California prisoner proceeding without a lawyer, filed a civil-rights complaint under 42 U.S.C. § 1983. The complaint named two judicial officers and a clerk as defendants and challenged their involvement in dismissing Broadnax’s prior lawsuit or lawsuits.

Screening standard

Because a prisoner sued governmental actors, the court conducted the preliminary review required by 28 U.S.C. § 1915A. That law requires dismissal of claims that are frivolous, malicious, fail to state a claim for relief, or seek money from a defendant who is immune from that relief. The court also applied the requirement that a complaint provide enough factual matter to state a plausible claim, while construing a self-represented litigant’s pleadings liberally.

Immunity analysis

The court held that judges have absolute immunity from civil liability for damages for acts performed in their judicial capacity. That protection also extends to people, including clerks, who perform functions necessary to the judicial process. The court determined that dismissing a case is a judicial act and that the clerk’s involvement was a function necessary to the judicial process. It therefore concluded that the defendants were absolutely immune from liability for their involvement in dismissing Broadnax’s prior lawsuit or lawsuits.

Disposition

The court dismissed the case for failure to state a claim upon which relief may be granted. It directed the clerk to enter judgment and close the file. Judge Jeffrey S. White signed the order on August 18, 2023.