Partridge v. Masley

Background

Nicholas D. Partridge, appearing without a lawyer, filed the action under the court’s federal-question jurisdiction. He sued Andrea Masley, a judge of the New York State Supreme Court, New York County. Partridge alleged “Discrimination by Law due to Judge Andrea Masley decision” in an earlier state-court lawsuit in which she entered judgment for the defendant. His requested relief included 25% ownership of an entity that he said the New York City Police Department wanted to control, if Judge Masley wanted to take control of the Muhammad Ali Humanitarian Center in Kentucky, and $1 million for alleged discrimination connected to his grandfather’s Vietnam War service and Judge Masley’s decision.

The court had previously allowed Partridge to proceed without prepaying filing fees. Because he proceeded this way, the court was required to screen the complaint and dismiss it if it was frivolous, failed to state a claim, sought money from an immune defendant, or presented claims over which the court lacked jurisdiction.

Reasons for Dismissal

The court applied judicial immunity. This doctrine generally gives judges absolute protection from lawsuits seeking damages for actions taken within their judicial responsibilities. The court explained that actions arising from or related to individual cases before a judge are ordinarily judicial acts. Immunity does not apply when a judge acts outside the judge’s judicial capacity or without any jurisdiction, but the court found that Partridge alleged no facts showing either circumstance. It therefore dismissed his claims against Judge Masley under the federal statute governing screening of complaints filed without prepayment of fees, finding them barred by judicial immunity and consequently frivolous for purposes of that statute.

The court separately held that the requested injunctive relief was barred by the Anti-Injunction Act. That federal law generally prohibits a federal court from ordering a halt to state-court proceedings unless one of three statutory exceptions applies. The court found that Partridge had alleged nothing showing that an exception permitted federal intervention.

Disposition

The court dismissed the complaint under the doctrine of judicial immunity and as prohibited by the Anti-Injunction Act. It also certified that any appeal would not be taken in good faith and denied Partridge permission to proceed without prepaying fees for purposes of an appeal.