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Cage v. Nixon
3:24-cv-01082
M.D. Tenn.
Mar 11, 2025
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Background

  • Plaintiff Quinton A. Cage, a Tennessee prisoner, was convicted in 1994 of several serious crimes and sentenced to 55 years.
  • Cage previously pursued multiple (at least eight) federal habeas petitions and other civil actions, all unsuccessful.
  • He was designated a "frivolous filer" and barred from proceeding in forma pauperis due to repeated meritless filings.
  • In this current action, Cage sues retired federal judges Haynes and Nixon, as well as the United States, alleging unfair rulings in his previous cases.
  • Plaintiff seeks monetary, declaratory, and injunctive relief, including an apology from Judge Nixon.
  • The Court considered whether the complaint states a valid legal claim against the defendants.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Are federal judges liable under § 1983? Judges issued "bogus rulings" violating his rights Judges are not state actors under § 1983 No liability; § 1983 only applies to state actors
Is there a Bivens cause of action against US/officials? Constitutional rights violated by judges/US Sovereign immunity bars suit; Bivens inapplicable No Bivens claim recognized here
Should Bivens be extended beyond past contexts? Plaintiff's claim should be recognized Bivens strictly limited to specific instances Claim exceeds recognized Bivens context
Do judges have immunity for judicial acts? Rulings were erroneous/bad faith Judicial immunity for official acts Judges immune for acts in judicial capacity

Key Cases Cited

  • Haines v. Kerner, 404 U.S. 519 (pro se pleadings construed liberally, but limits exist)
  • Boag v. MacDougall, 454 U.S. 364 (leniency for pro se litigants is not unlimited)
  • Pierson v. Ray, 386 U.S. 547 (judges have absolute judicial immunity)
  • Mireles v. Waco, 502 U.S. 9 (judicial immunity even for erroneous or malicious acts)
  • Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388 (created limited cause of action against federal officials for constitutional torts)
Read the full case

Case Details

Case Name: Cage v. Nixon
Court Name: District Court, M.D. Tennessee
Date Published: Mar 11, 2025
Docket Number: 3:24-cv-01082
Court Abbreviation: M.D. Tenn.