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