Constantin v. Navarrete

Background

Mitchel Constantin represented himself. He sued Jorge E. Navarrete, identified as the Clerk and Executive Officer of the California Supreme Court, over events involving Constantin’s child-support appeal and related filings in the California courts.

Constantin alleged that he has autism spectrum disorder and anxiety disorder and has difficulty understanding court procedures, communicating, concentrating, and obtaining help. In November 2021, while his state appeal was pending, he asked the California Supreme Court for permission to file a 471-page petition to transfer his appeal to that court. He also filed a disability-accommodation request seeking help with oral argument and court processes. The California Supreme Court denied the oversized-petition application the day it was filed. Navarrete later sent Constantin letters stating that the court would not reconsider the application, explain the reason for its denial, or consider further requests because the case was closed.

Constantin sued under Title II of the Americans with Disabilities Act, which prohibits disability discrimination by public entities. He also brought claims under 42 U.S.C. § 1983, a statute that allows suits against people acting under state authority for violating federal rights. His constitutional allegations involved the First Amendment rights to speak and petition, Fourteenth Amendment due process, and alleged failure to train court employees to comply with disability and constitutional requirements. He sought damages, declarations, and injunctions, including relief concerning other people with intellectual and developmental disabilities.

Judicial notice

The court granted Navarrete’s request to recognize the dockets and the existence of materials filed in Constantin’s California Supreme Court and Court of Appeal proceedings as public records. The court also recognized the current status of those proceedings. It denied Navarrete’s request concerning an order in an unrelated case and denied Constantin’s request concerning a brief filed in another unrelated case because those materials were not proper subjects for judicial notice.

Reasons for dismissal

The court applied Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint alleges enough facts to support a legally recognized claim. The court was required to accept material factual allegations as true at this stage and to read Constantin’s self-represented complaint liberally, but legal conclusions and speculative allegations were insufficient.

The court held that quasi-judicial immunity protected Navarrete from damages claims based on his communications conveying the California Supreme Court’s decisions about Constantin’s oversized petition and later requests for reconsideration or clarification. Quasi-judicial immunity is protection from liability for people performing functions closely connected to the judicial process. The court explained that this protection can apply to court clerks when they perform tasks integral to that process or at a judge’s direction.

The court distinguished administrative handling of disability-accommodation requests, which may not receive the same protection. But it concluded that the communications challenged here reflected Navarrete’s communication of court decisions about the petition rather than separate administrative decisions. The court also stated that, to the extent Constantin claimed the disability required permission to file hundreds of extra pages, his complaint did not plausibly connect his disability to the need for that accommodation. The court separately noted that the California Supreme Court had not reached Constantin’s requests for help with oral argument or court processes because it did not accept the nonconforming petition in the first instance.

The court held that Navarrete could not be individually liable under Title II of the Americans with Disabilities Act because that law applies to public entities, not individuals. The court also agreed that § 1983 could not be used to enforce rights protected by the disability statute. It clarified, however, that Constantin could use § 1983 to assert separate First and Fourteenth Amendment violations based on the same or similar facts. The court concluded that Constantin’s § 1983 claim based specifically on alleged failure to train employees to accommodate disabilities could not proceed insofar as it sought to enforce Title II rights.

The court also ruled that Constantin lacked standing—an adequate legal connection to seek the requested future relief—for his requested ADA injunctions and declarations. The state proceedings had ended, and the records did not show that Constantin was likely to face the same alleged conduct again. His request for relief benefiting other people with disabilities was likewise unsupported by allegations establishing a basis for that relief.

As to the § 1983 claims, the court held that Constantin could not obtain an injunction against Navarrete in his official capacity as Clerk of the California Supreme Court for the alleged constitutional violations. The court did not decide whether the statutory restriction on injunctions against judicial officers also covers prospective declaratory relief because Constantin sought declarations about past actions, not an order addressing an ongoing violation.

Disposition

The court concluded that the complaint failed to state a claim for relief against Navarrete. It granted Navarrete’s motion to dismiss and dismissed the complaint with leave to amend. The court allowed Constantin to file an amended complaint no later than October 6, 2023, and stated that he could not add new claims or parties without the court’s permission.