Williams v. Clott

Background

Tearre Williams, who appeared without a lawyer, sued New York County Assistant District Attorney Christopher Mills and Justice Abraham Clott of the New York State Supreme Court, New York County. Williams alleged that Mills and Justice Clott acted outside his presence on March 23 and 24, 2021, in connection with his pending state criminal proceeding. His allegations referred to being removed from a court date, being indicted, having a warrant issued, and being prevented from presenting witnesses. The complaint did not clearly identify the relief Williams sought.

The court interpreted the complaint as asserting civil-rights claims for damages and court orders under 42 U.S.C. § 1983, as well as a claim under 28 U.S.C. § 2241 seeking a federal order concerning his custody. The court noted that Williams had been released on bail while his criminal proceeding continued.

Claims Against Justice Clott

The court dismissed the § 1983 claims against Justice Clott under judicial immunity and as frivolous. Judicial immunity generally protects judges from damages suits for actions taken within their judicial responsibilities, including actions arising from cases before them. The court determined that Williams’s allegations concerned Justice Clott’s decisions and actions while presiding over Williams’s criminal proceeding.

The court also concluded that Williams could not obtain injunctive relief against Justice Clott under § 1983. That statute generally bars such relief against a judicial officer unless a declaratory decree was violated or declaratory relief was unavailable. The court stated that Williams could appeal Justice Clott’s decisions through the New York state courts, making declaratory relief available there.

Claims Against Mills

The court dismissed Williams’s § 1983 claims for damages against Mills under prosecutorial immunity and as frivolous. Prosecutorial immunity generally protects prosecutors from damages suits for actions within their official duties that are closely connected to the judicial phase of a criminal prosecution. The court found that Williams’s claims against Mills arose from Mills’s prosecution of Williams.

Requests to Interfere With the State Criminal Case

To the extent Williams sought § 1983 injunctive relief that would cause the federal court to intervene in his pending state criminal proceeding, the court dismissed those claims under the Younger abstention doctrine. That doctrine generally requires federal courts to refrain from enjoining ongoing state criminal prosecutions unless special circumstances—such as bad faith, harassment, or serious and immediate irreparable injury—are shown. The court found that Williams had not alleged facts establishing those circumstances.

Custody Challenge

The court construed Williams’s allegations about the legality of his custody as a request for relief under 28 U.S.C. § 2241. It explained that a state criminal defendant released on bail can be considered “in custody” for this purpose. But before seeking federal relief, the defendant generally must exhaust available state-court remedies, including pursuing state habeas relief and, if necessary, appealing to the New York Court of Appeals.

Because Williams did not show that he had exhausted available state remedies, the court dismissed his § 2241 custody claims without prejudice. The court therefore did not reach the merits of whether Williams’s custody violated federal law.

Leave to Amend and Disposition

The court denied Williams leave to file an amended complaint. Although self-represented plaintiffs are ordinarily given an opportunity to amend when a valid claim might be stated, the court concluded that many of Williams’s claims were frivolous and that amendment would be futile.

The court dismissed the action. It dismissed the § 1983 claims as frivolous, under judicial and prosecutorial immunity, and under Younger abstention. It dismissed the § 2241 custody claims without prejudice. The court also declined to issue a certificate of appealability and certified that an appeal would not be taken in good faith, so Williams was denied a filing-fee waiver for an appeal.