Washington v. United States

Background

April Washington, appearing without a lawyer, sued the United States, the “Federal Administration of Employees,” and the “United States District of Columbia Supreme Court.” The complaint made clear that she was actually challenging the Supreme Court and its employees. She alleged that the handling of her earlier cases and petition for review involved fraudulent documents, incorrect docket information, and other misconduct. She asserted that defendants violated her rights under the Fourteenth Amendment and sought money damages, relief from an earlier judgment under Rule 60(b), relief under the Federal Tort Claims Act, and mandatory arbitration.

The complaint also named Jordan Washington as a plaintiff. The court noted that the complaint and attachments generally described events involving April Washington’s cases, that Jordan Washington had not signed the complaint, and that Jordan had not submitted an application to proceed without prepaying fees.

Claims on Jordan Washington’s behalf

The court held that a person who is not a licensed attorney may not represent another person in that person’s claims. It therefore dismissed any claims brought on behalf of Jordan Washington without prejudice. The court stated that references to “Plaintiff” in the remainder of the order meant April Washington.

Judicial immunity and screening

Because April Washington was allowed to proceed without prepaying fees, the court was required to dismiss claims that were frivolous, failed to state a claim, or sought money from an immune defendant. It also had to dismiss claims over which it lacked subject-matter jurisdiction.

The court applied judicial immunity, which generally protects judges from damages lawsuits for actions taken as part of their judicial responsibilities. The protection also extends to court clerks and others performing functions closely connected to the judicial process. The court concluded that issuing decisions, managing the Supreme Court’s docket, and addressing matters connected to individual cases are judicial activities. It therefore ruled that April Washington’s claims concerning the denial of her petition, responses to her questions, docket information, and allegedly duplicated docket numbers were barred by judicial immunity.

The court dismissed April Washington’s complaint under the filing-fee screening statute as barred by judicial immunity and as frivolous. It also noted that sovereign immunity could provide another basis for dismissal and explained that the Federal Tort Claims Act requires administrative exhaustion and does not waive immunity for constitutional-tort claims. The court did not rely on those points as the stated basis for the final dismissal.

Other requests and disposition

The court denied April Washington’s request for relief under Rule 60(b) from the Eastern District of Virginia judgment, explaining that such a request ordinarily must be filed in the court that entered the judgment. It declined to grant leave to amend because it found that the complaint’s defects could not be cured by amendment.

The final order dismissed April Washington’s complaint under 28 U.S.C. § 1915(e)(2)(B)(i) and (iii). It dismissed Jordan Washington’s claims without prejudice and stated that all other matters were terminated. The court also certified that an appeal would not be taken in good faith and denied fee-free status for an appeal.