Campbell McGagh v. The Supreme Court of Maryland
1:24-cv-01015
D. MarylandSep 6, 2024Background
- Plaintiff Karen Elizabeth Campbell McGagh, acting pro se, sued the Maryland Supreme Court, its seven Justices, Governor Wes Moore, and other state officials.
- McGagh alleges the Supreme Court of Maryland committed perjury by reinstating her criminal conviction previously overturned by Maryland's Court of Special Appeals.
- She filed a motion for a Temporary Restraining Order (TRO) to prevent the Maryland Supreme Court from engaging in alleged off-the-record and unofficial case negotiations.
- Federal District Judge Matthew J. Maddox reviewed the request for the TRO without a hearing, applying the standard four-factor test for injunctive relief.
- Judge Maddox addressed both judicial and sovereign immunity as defenses shielding the defendants from suit over official duties.
- The Court also ruled on a related document seeking preservation of evidence, concluding it was not properly before the Court as a motion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Entitlement to TRO | Off-the-record court activities violate plaintiff's rights | Judicial and sovereign immunity apply; proper conduct within official roles | TRO denied; plaintiff does not meet all injunctive relief factors |
| Likelihood of Success | Reinstatement of conviction was wrongful and involved misconduct | Actions taken were official judicial acts, covered by immunity doctrines | No likelihood of success due to absolute and sovereign immunity |
| Irreparable Harm | Will suffer unspecified harm if state court continues current practices | Claimed harms are speculative and not imminent | No irreparable harm demonstrated |
| Public Interest and Balance of Equities | Injunction needed to protect legal integrity | Federal intervention would breach principles of federalism and comity | TRO against state court would undermine public interest |
Key Cases Cited
- Gibson v. Goldston, 85 F.4th 218 (4th Cir. 2023) (affirming strength of judicial immunity from civil suits for official acts)
- Stump v. Sparkman, 435 U.S. 349 (1978) (judges immune for judicial acts, even if in error or taken maliciously)
- Bradley v. Fisher, 80 U.S. 335 (1872) (root of U.S. judicial immunity doctrine from civil liability for official acts)
- Godwin v. Cnty. Com’rs of St. Mary's Cnty., 260 A.2d 295 (Md. 1970) (sovereign immunity protecting state officials in discharge of official duties)
- Direx Israel, Ltd. v. Breakthrough Med. Grp., 952 F.2d 802 (4th Cir. 1991) (standard for irreparable harm in preliminary injunctions)