Battle v. Washington
2:25-cv-11322
| E.D. Mich. | May 28, 2025Background
- Plaintiff, Ah’Nice Nekol-Andrea Battle, brought suit against three Michigan state court judges, the owner of her former apartment complex, and the complex's attorney.
- The complaint alleged constitutional and civil rights violations related to adverse decisions and conduct by the defendants during prior state court litigation, which stemmed from Battle's attempt to rescind a residential lease.
- The federal claims included due process violations, abuse of power, conspiracy to violate civil rights, and unlawful seizure.
- The court conducted an initial screening under 28 U.S.C. §§ 1915(e)(2), 1915A, and found the complaint failed to state viable claims.
- The court also addressed whether to exercise supplemental jurisdiction over remaining state-law claims.
- Plaintiff had moved for a temporary restraining order; the court terminated this motion as moot.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial Immunity | Judges acted improperly, denied due process, lacked jurisdiction | Judges immune for judicial acts | Judges are immune; no facts pled to overcome immunity |
| State Action (Section 1983) | Attorney and landlord violated constitutional rights | Not state actors | Not liable under § 1983; no state action alleged |
| Section 1985 Conspiracy | All defendants conspired to deprive civil rights | No conspiracy or animus | Dismissed; no facts showing class-based animus |
| Supplemental Jurisdiction | Federal court should hear state-law claims | Federal claims dismissed | Declined supplemental jurisdiction over state claims |
Key Cases Cited
- Denton v. Hernandez, 504 U.S. 25 (standard for frivolity under IFP statute)
- Neitzke v. Williams, 490 U.S. 319 (standard for failure to state a claim)
- Haines v. Kerner, 404 U.S. 519 (liberal construction of pro se complaints)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards; conclusory allegations insufficient)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (Rule 8 pleading standard)
- Mireles v. Waco, 502 U.S. 9 (scope of judicial immunity)
- Stump v. Sparkman, 435 U.S. 349 (judicial immunity not lost for alleged error or malice)
- American Manufacturers Mutual Ins. Co. v. Sullivan, 526 U.S. 40 (Section 1983 applies only to state actors)
- Griffin v. Breckenridge, 403 U.S. 88 (Section 1985 requires class-based discriminatory animus)