585 F.Supp.3d 194
D. Conn.2022Background
- In August 2017 Tacara Campbell asked friend Robert Bowens to take her car for repairs; Bowens was arrested on drug charges and police seized the car.
- Connecticut initiated a civil forfeiture action; Bowens signed a stipulation in September 2018 (counter-signed by prosecutor Cynthia Serafini) that purported to waive claims and "donate" the car to police; a judgment followed and was later amended.
- Campbell contends she never received notice of the stipulation or amended judgments and that she did not authorize her name to be included; she appeared in court in November 2017 to assert ownership.
- In August 2020 Campbell moved to open the judgment; in December 2020 she entered a stipulation providing return of the car upon payment of $500; she alleges police/storage facility have not complied and the car was damaged in storage.
- Campbell filed this federal suit asserting a federal Takings Clause claim (via § 1983), a state constitutional takings claim, and state tort claims against the Connecticut Judicial Branch, prosecutor Serafini, and deputy court clerk Laura Leigh (among other defendants).
- The State defendants moved to dismiss; the district court granted dismissal based on Eleventh Amendment sovereign immunity, prosecutorial and clerk immunities, and Connecticut statutory immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Connecticut Judicial Branch can be sued in federal court for Takings and parallel state claims | Campbell seeks federal takings relief against Judicial Branch | Judicial Branch invokes Eleventh Amendment sovereign immunity; no waiver or congressional abrogation | Dismissed: Eleventh Amendment bars suit; state forums available for takings claims |
| Whether official-capacity claims against Serafini and Leigh proceed under Ex Parte Young or otherwise | Campbell contends ongoing policy/practice compels payment of high storage fees; seeks declaratory/prospective relief | Defendants assert Eleventh Amendment bars official-capacity suits; Ex Parte Young inapplicable (no ongoing violation by these officials or authority to effect return) | Dismissed: official-capacity claims barred; Campbell lacks standing for broad policy challenge given her $500 stipulation |
| Whether Serafini is liable in her individual capacity under § 1983 Takings Clause (prosecutorial act of signing stipulation) | Campbell argues Serafini improperly extinguished an innocent owner interest and exceeded authority | Serafini asserts absolute prosecutorial immunity for acts intimately associated with judicial process | Dismissed: Serafini entitled to absolute prosecutorial immunity for signing the stipulation; no showing she acted palpably beyond authority |
| Whether Leigh is liable in her individual capacity under § 1983 Takings Clause for failing to notify Campbell of stipulation/judgments | Campbell faults Leigh for failing to serve notice of stipulation and judgments | Leigh asserts lack of personal involvement in any taking and absolute (or at least qualified) immunity as court clerk; no clearly established ministerial duty shown | Dismissed: insufficient personal involvement; clerk immune (absolute or, alternatively, qualified immunity applies); state statutory immunity also bars state-law claims |
Key Cases Cited
- Imbler v. Pachtman, 424 U.S. 409 (absolute immunity for prosecutors in prosecutorial functions)
- Quern v. Jordan, 440 U.S. 332 (§ 1983 does not abrogate state sovereign immunity)
- Knick v. Township of Scott, 139 S. Ct. 2162 (state takings doctrine and exhaustion discussion; does not displace Eleventh Amendment analysis)
- Ex Parte Young, 209 U.S. 123 (permits prospective injunctive relief against state officers for ongoing federal violations)
- City of Los Angeles v. Lyons, 461 U.S. 95 (standing limits for injunctive relief absent likelihood of future harm)
- Hafer v. Melo, 502 U.S. 21 (individual-capacity suits against state officials not barred by Eleventh Amendment)
- Rodriguez v. Weprin, 116 F.3d 62 (absolute immunity for clerks for acts integral to judicial process)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for pleadings)