Ruiz v. U.S. Federal Courthouse 40 Foley Square 104

Background

Angel Ruiz, who was proceeding without a lawyer, filed the action and requested $10 million in damages. He named the U.S. Federal Courthouse at 40 Foley Square and United States District Judge Valerie E. Caproni as defendants. Ruiz referred to disability, gay-rights, and immigration-rights issues and purported to invoke both diversity and federal-question jurisdiction.

Ruiz alleged that, in January 2018, he and his partner went to the courthouse for a proceeding before Judge Caproni. While Ruiz was sitting on a walker and waiting to pass through a metal detector, he suffered a seizure and fell. He alleged that five federal police officers prevented his partner from helping him and that one officer lifted and punched him, causing him to fall again and injure his left shoulder. Ruiz alleged that he was taken to a hospital and later experienced chronic pain, disability, and other health problems that prevented him from working.

Ruiz also alleged that he asked the court and Judge Caproni to report the incident, but they refused. He claimed that Judge Caproni ignored or covered up the incident and made improper decisions in an earlier related case. The opinion also notes that Ruiz had filed a separate related action concerning the alleged courthouse injuries. In that action, the court had addressed possible claims under the Federal Tort Claims Act, the federal constitutional damages theory recognized in Bivens, the Rehabilitation Act, and state law, and had allowed some amendment while dismissing the Bivens claims as untimely.

Court’s analysis

Because Ruiz had been allowed to proceed without paying filing fees, the court was required to dismiss claims that were frivolous, failed to state a legally sufficient claim, sought damages from an immune defendant, or fell outside the court’s subject-matter jurisdiction. The court also was required to read a self-represented litigant’s allegations liberally, while still requiring enough factual detail to make a claim plausible.

Claims against Judge Caproni for failing to investigate or protect Ruiz. The court treated these as claims for damages under Bivens. It held that government officials generally have no constitutional duty to investigate an incident or protect an individual from harm. The court identified exceptions for custody situations and for officials who affirmatively create or increase a danger, but found that Ruiz had not alleged facts showing that either exception applied. The court therefore dismissed these claims for failure to state a claim.

Conspiracy claims against Judge Caproni. The court understood Ruiz to allege that Judge Caproni conspired with unidentified people to cover up the courthouse incident. It held that the allegations were vague, conclusory, and lacked sufficient detail to show an agreement, coordinated unconstitutional conduct, and an act causing damages. The court also relied on its conclusion that Judge Caproni had no constitutional duty to investigate or protect Ruiz. It dismissed the conspiracy claims for failure to state a claim.

Claims based on Judge Caproni’s judicial decisions. The court held that judicial immunity generally protects judges from damages claims based on actions taken within their judicial responsibilities, even when a plaintiff alleges bad faith or malice. It found no indication that the alleged actions in the earlier related case were outside Judge Caproni’s judicial capacity or taken without jurisdiction. The court dismissed these claims under judicial immunity and consequently treated them as frivolous for purposes of the fee-waiver statute.

Requests for criminal prosecution. To the extent Ruiz sought to have others criminally prosecuted, the court dismissed those claims for lack of subject-matter jurisdiction. The court explained that private individuals cannot initiate criminal prosecutions or direct prosecutors to bring charges.

Claims against the courthouse. To the extent Ruiz sought to bring Federal Tort Claims Act claims against the United States based on the January 2018 incident, the court dismissed those claims without prejudice to Ruiz pursuing them in the related action. To the extent he sought constitutional damages under Bivens from the courthouse itself, the court dismissed those claims for failure to state a claim because Bivens claims may be brought only against federal officers in their individual capacities, and the courthouse is not a federal officer.

Disposition

Judge Laura Taylor Swain dismissed the action. The court denied Ruiz leave to amend because it concluded that the complaint’s defects could not be cured by amendment. It directed the Clerk of Court to enter judgment dismissing the action. The court also certified that any appeal would not be taken in good faith and denied Ruiz permission to proceed without prepaying appellate fees.

Effect of the order

The order ended this action. The Federal Tort Claims Act claims concerning the courthouse incident were dismissed without prejudice to pursuing them in the related case identified by docket number 1:23-CV-7421 (LTS).