Angela McCullough v. Ernest N. Finley, Jr.
907 F.3d 1324
| 11th Cir. | 2018Background
- A putative class of indigent Montgomery, AL residents sued after being jailed for failure to pay municipal fines and forced to work to reduce jail time; they alleged a city-wide scheme to raise revenue via imprisonment and coerced labor.
- Defendants named: two municipal judges (Westry, Hayes), the mayor (Strange), and two police chiefs (Finley, Murphy), plus the City and a private probation company; plaintiffs alleged peonage (18 U.S.C. §§ 1589, 1595) and false imprisonment under state law.
- Complaint principally grouped defendants and alleged broad policies (e.g., ticket-stacking, lack of meaningful indigency hearings, forced work program) but provided few facts tying the mayor or chiefs individually to the alleged scheme.
- District court denied motions to dismiss based on asserted immunities; defendants appealed the denials of judicial, qualified, and state-agent immunity (City’s interlocutory appeal was dismissed for lack of jurisdiction).
- Eleventh Circuit reviewed de novo, applying Twombly/Iqbal plausibility standards when immunity defenses were invoked.
- Court held that the judges were entitled to absolute judicial immunity for judicial acts (including sentencing, indigency hearings, probation terms), and that plaintiffs failed to plead facts sufficient to overcome qualified/state-agent immunity for the mayor and chiefs.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether municipal judges are immune from suit for ordering jailed "sit-out" sentences and related courtroom actions | Judges acted as part of a revenue-generating scheme; acted maliciously/corruptly, so not immune | Judges performed judicial acts within jurisdiction and thus have absolute judicial immunity | Judges enjoy absolute judicial immunity; claims barred because acts were judicial and within subject-matter jurisdiction |
| Whether mayor and police chiefs can be held liable under federal anti-peonage statutes and state false imprisonment claims | Mayor and chiefs adopted/administered policies that coerced labor and imprisonment to raise revenue; they acted intentionally and in bad faith | Allegations are conclusory and fail to plead specific facts showing personal involvement or knowledge; qualified/state-agent immunity applies | Plaintiffs’ allegations are conclusory; after Iqbal/Twombly scrutiny, complaint fails to plausibly allege personal conduct to overcome qualified or state-agent immunity |
| Whether conclusory/group allegations suffice to defeat immunity at motion-to-dismiss stage | Group-based allegations and municipal revenue disparities support inference of a coordinated scheme | Iqbal/Twombly require factual enhancement; group labels are insufficient | Court rejects group/conclusory allegations; factual specificity required to overcome immunity |
| Whether municipal revenue disparities (vs. comparable city) support inference of illicit scheme | Elevated fine/cost revenue in Montgomery vs. Huntsville supports inference of a revenue scheme | Revenue differences have plausible alternative explanations; not enough to plead conspiracy or supervisory liability | Revenue statistics alone do not raise plaintiffs’ claims from conceivable to plausible |
Key Cases Cited
- Stump v. Sparkman, 435 U.S. 349 (judge immune for judicial acts)
- Mireles v. Waco, 502 U.S. 9 (judicial-act focus for immunity analysis)
- Dykes v. Hosemann, 776 F.2d 942 (11th Cir.) (factors for judicial immunity)
- Forrester v. White, 484 U.S. 219 (distinguishing judicial from administrative acts)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards; conclusory allegations insufficient)
- Bell Atlantic v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Sibley v. Lando, 437 F.3d 1067 (judicial activity analysis)
- Franklin v. Curry, 738 F.3d 1246 (qualified immunity framework at motion-to-dismiss)
- Hill v. Cundiff, 797 F.3d 948 (Alabama state-agent immunity standard)
- Carollo v. Boria, 833 F.3d 1322 (applying Twombly/Iqbal where immunity asserted)
- Morrison v. Lipscomb, 877 F.2d 463 (distinguishing non-judicial general orders)
- Scott v. Dixon, 720 F.2d 1542 (malicious motivation does not defeat judicial immunity)
- Owens v. Kelley, 681 F.2d 1362 (probation terms are judicial acts)
- Eggar v. City of Livingston, 40 F.3d 312 (advising indigent defendants is a judicial act)
- Davis v. Tarrant County, 565 F.3d 214 (appointment/failure to appoint counsel is judicial)
- Harris v. Deveaux, 780 F.2d 911 (ordering incarceration is judicial)