Colliton v. D'Alessio

Background

James Colliton, who was representing himself, sued Justice Christie D’Alessio and the Supreme Court of the State of New York, Dutchess County. The claims arose from a state-court debt-collection case brought against Colliton by Credit Corp. Solutions, Inc. Colliton had filed an answer, a counterclaim, and a motion seeking judgment based on Credit Corp.’s failure to respond.

Justice D’Alessio later transferred the case, including Colliton’s counterclaim, to the Poughkeepsie City Court. Before the transfer, Colliton had told a court clerk that he had a disability and needed communications by mail because he did not use a computer. Colliton alleged that disability discrimination was the only explanation for the transfer and objected to the different filing fees in the two courts. He requested damages, return of $140 in fees, and a federal ruling concerning the state judge’s treatment of him.

The court had previously allowed Colliton to proceed without paying filing fees in advance. It therefore reviewed the complaint under the statute requiring dismissal of such complaints that are frivolous, fail to state a claim, or seek money from an immune defendant.

Claims Against Justice D’Alessio

The court held that judicial immunity barred Colliton’s claims for damages against Justice D’Alessio. Judicial immunity generally protects judges from damages suits based on acts performed as part of their judicial responsibilities, including acts related to cases before them. The court found that transferring the state-court action was a judicial act and that Colliton alleged no facts showing that Justice D’Alessio acted outside judicial responsibilities or without jurisdiction.

The court therefore dismissed the claims against Justice D’Alessio because they sought monetary relief from a defendant immune from that relief. The court also noted that lower federal courts cannot review state-court decisions; within the federal court system, only the United States Supreme Court may review those decisions.

Disability-Discrimination Claims

The court interpreted Colliton’s allegations as claims under Title II of the Americans with Disabilities Act and Section 504 of the Rehabilitation Act. Both laws prohibit certain forms of disability discrimination, although the Rehabilitation Act also requires that the relevant program receive federal funding.

The court concluded that Colliton’s allegations did not plausibly connect his disability to the transfer order. The complaint did not identify a factual link between his conversation with the clerk and Justice D’Alessio’s decision to transfer the case. The court also stated that Colliton’s assertion that disability discrimination was the “sole explanation” for the transfer was an unsupported inference rather than a factual basis for the claim. The court therefore held that the complaint failed to state a claim under either disability-discrimination law.

Disposition

The court dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(ii) and (iii), which address failure to state a claim and seeking monetary relief from an immune defendant. It declined to allow amendment because it found that the defects could not be cured. The court also certified that any appeal would not be taken in good faith and denied permission to appeal without prepaying fees. The Clerk of Court was directed to enter judgment.