Caldwell v. Obama
2013 U.S. Dist. LEXIS 164953
| D.D.C. | 2013Background
- Caldwell filed a fifth pro se complaint naming numerous federal officials, a private university, and others alleging due process and related harms from prior cases.
- The court dismissed the action sua sponte under Rule 12(b)(6) and claim preclusion, due to failure to state a claim and prior final judgments.
- The defendants include President Obama, AG Holder, Education Secretary Duncan, IRS officials, various judges, Argosy University, and its president.
- Prior lawsuits (Caldwell I–IV) spanned Tax Court, DC federal courts, and the Supreme Court, arising from tax refunds and disputes with Argosy University.
- The court found that many claims were barred by absolute immunity for judges, lack of standing, or failure to plead viable constitutional claims, among other defects.
- The court also issued a pre-filing injunction, barring Caldwell from filing new complaints in this court without prior leave.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the complaint states a claim under Rule 12(b)(6). | Caldwell asserts due process and related rights against officials. | Defendants contend the claims are not plausible and fail to state a claim. | The complaint is dismissed for failure to state a claim. |
| Whether federal judges enjoy absolute immunity from such suits. | Judges violated rights by decisions in Caldwell I–IV. | Judges acted in their official capacities; immunity bars suit. | Claims against judicial defendants are dismissed due to absolute immunity. |
| Whether Caldwell's claims against executive officials under 42 U.S.C. § 1983/Bivens are viable. | Executive actions violated due process and related rights. | Bivens/§1983 claims fail due to lack of state action and no viable rights violation. | Fourth COA dismissed; no plausible Bivens/§1983 claim. |
| Whether the Seventh COA is barred by claim preclusion. | DOE/USAO/Argosy allegations of mismanagement. | Claims restate prior dismissed claims; precluded. | Seventh COA dismissed due to claim/issue preclusion. |
| Whether a pre-filing injunction is warranted to bar further filings absent leave. | Continued litigation is justified to recover due process rights. | Filing pattern is harassing and duplicative; injunctive relief appropriate. | Pre-filing injunction issued; Caldwell barred from filing new actions without court permission. |
Key Cases Cited
- Forrester v. White, 484 U.S. 219 (U.S. 1988) (absolute immunity for judges in official acts)
- Stump v. Sparkman, 435 U.S. 349 (U.S. 1978) (judicial immunity protects acts within judicial function)
- Sindram v. Suda, 986 F.2d 1459 (D.C. Cir. 1993) (confirming absolute immunity for judges)
- Jones v. Horne, 634 F.3d 588 (D.C. Cir. 2011) (test for qualified immunity analysis)
- Pearson v. Callahan, 555 U.S. 223 (U.S. 2009) (clarified Saucier sequence for qualified immunity)
- Morrissey v. Brewer, 408 U.S. 471 (U.S. 1972) (due process requires a meaningful opportunity to be heard)