Farrar v. Michell
- Louis Stanton
- 1:20-cv-03762
- U.S. District Court · Southern District of New York
- 4
In Farrar v. Michell, Judge Stanton dismissed Farrar’s damages complaint against a judge as barred by judicial immunity and frivolous.
Shanice Farrar’s complaint was dismissed, and Justice Mitchell J. Danzinger was protected from the damages claims by judicial immunity.
What happened
In Farrar v. Michell, Shanice Farrar, representing herself, sued after her 14-year-old son was killed by police and sought damages related to a later wrongful-death lawsuit. The opinion says the complaint was unclear about what happened in that lawsuit.
Farrar named Danziger Michell as the only defendant, and the court inferred that she meant New York state judge Mitchell J. Danzinger, who had presided over the wrongful-death case. She sought more than $21 million in damages.
Judge Louis L. Stanton dismissed the complaint under judicial immunity and as frivolous. The court held that judges are generally immune from damages lawsuits for actions taken as part of their judicial duties, and it declined to allow Farrar to amend because the defects could not be fixed.
The detailed version
- Farrar v. Michell · No. 1:20-cv-03762
- Louis Stanton
- Sept. 3, 2020
Background
Shanice Farrar filed the action without a lawyer and received permission to proceed without paying filing fees in advance. She alleged that the defendant violated her rights. The court understood the complaint to allege that Farrar’s 14-year-old son was killed by police on August 4, 2013, after which Farrar filed a wrongful-death action. The opinion states that the result of that action was unclear, but that Farrar appeared to disagree with events in the litigation.
The complaint named Danziger Michell as the sole defendant. The court inferred that Farrar intended to sue Justice Mitchell J. Danzinger, whom the court identified as the judge who presided over the wrongful-death action. Farrar sought monetary damages exceeding $21 million.
Legal standard
Because Farrar was proceeding without paying filing fees, the court was required to screen the complaint under 28 U.S.C. § 1915(e)(2)(B). That statute requires dismissal of a qualifying complaint that is frivolous or malicious, fails to state a claim for relief, or seeks money from a defendant who is immune from such relief. The court also noted that it must dismiss a case when it lacks authority to hear the subject matter.
The court explained that pleadings filed by people without lawyers are read generously, but they still must provide enough facts to make a legally plausible claim under Rule 8 of the Federal Rules of Civil Procedure.
Judicial immunity
The court held that Farrar’s claims against Justice Danzinger had to be dismissed under absolute judicial immunity. Judges are generally immune from damages lawsuits for actions taken within the scope of their judicial responsibilities, including actions arising from or related to cases before them. Allegations of bad faith or malice do not overcome that immunity.
The court noted two general limits on judicial immunity: it does not apply to actions taken outside a judge’s judicial capacity or to judicial actions taken when the judge lacked jurisdiction. But the court found that Farrar did not allege that Justice Danzinger acted outside his judicial capacity. The court also cited the statutory limits on injunctive relief against judicial officers under 42 U.S.C. § 1983.
Disposition
The court dismissed Farrar’s claims against Justice Danzinger under judicial immunity and as frivolous. It also declined to grant leave to amend because the defects could not be cured by amending the complaint. The order directed the Clerk of Court to mail Farrar a copy of the order and note service on the docket.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.