Reiss v. Baron
- Laura Swain
- 1:22-cv-00908
- U.S. District Court · Southern District of New York
- 5
In Reiss v. Baron, Judge Swain dismissed Reiss’s claims against two state judges, declined state-law jurisdiction, and denied leave to amend.
Karolina Anna Reiss’s damages claims against Judges Elena Baron and Denise M. Dominguez were dismissed. Any state-law claims were not considered after the federal claims were dismissed, and Reiss was denied leave to amend.
What happened
In Reiss v. Baron, Karolina Anna Reiss sued Judges Elena Baron and Denise M. Dominguez for damages based on their conduct during pretrial conferences in her pending state-court civil case. Reiss represented herself and asserted federal claims under Section 1983, along with possible state-law claims.
The court ruled that judicial immunity protected the judges from damages claims for actions taken while performing their judicial duties. It also declined to consider any remaining state-law claims after dismissing the federal claims.
Judge Laura Taylor Swain dismissed the action, denied Reiss leave to amend because amendment would be futile, and certified that an appeal would not be taken in good faith, denying fee-free appeal status.
The detailed version
- Reiss v. Baron · No. 1:22-cv-00908
- Laura Swain
- Mar. 3, 2022
Background
Karolina Anna Reiss, appearing without a lawyer, sued Elena Baron and Denise M. Dominguez in their individual capacities for damages. The opinion identifies both defendants as judges of the Civil Court of the City of New York, New York County. Reiss was a defendant and counterclaimant in a civil case pending in that court.
Reiss alleged that Judge Baron presided over a September 1, 2021, pretrial conference and prevented her from filing a motion to compel discovery, stating that discovery would be discussed at the next conference. Reiss also alleged that Judge Dominguez presided over a November 5, 2021, pretrial conference, limited Reiss’s ability to speak, tried to elicit an admission that she owed money connected to a credit-card loan, and allowed opposing counsel to state a settlement amount as though the case had already been decided.
The court construed the complaint as asserting claims under 42 U.S.C. § 1983 and state law.
Reasons for the ruling
The court dismissed the Section 1983 claims under the doctrine of judicial immunity and as frivolous. Judicial immunity generally gives judges complete protection from damages suits for actions taken within their judicial responsibilities. The opinion explains that this protection does not apply when a judge acts outside a judicial role or acts without any jurisdiction. The court concluded that Reiss’s claims arose from actions Baron and Dominguez took while presiding over pretrial conferences in Reiss’s state-court case, which were judicial acts.
After dismissing the federal claims, the court declined to exercise supplemental jurisdiction—the court’s authority to hear related state-law claims—over any state-law claims Reiss might be asserting. The court also denied Reiss leave to amend because it concluded that the defects in her complaint could not be cured by amendment.
Disposition
The court dismissed the action. It dismissed Reiss’s Section 1983 claims under judicial immunity and as frivolous, declined to consider any state-law claims under supplemental jurisdiction, and denied leave to amend. The court also certified that any appeal would not be taken in good faith and denied fee-free appeal status. The opinion does not state that the dismissal was with or without prejudice.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.