Chamberlain v. Bryson
236 F. Supp. 3d 425
D.D.C.2017Background
- Plaintiff (Chamberlain) filed suit in D.C. Superior Court alleging Judge William C. Bryson conspired to commit murder and sought all savings/property/earnings.
- Amended complaint tied Bryson to the alleged conspiracy and referenced actions related to Chamberlain’s appeal in the Federal Circuit (No. 2016-1603).
- Judge Bryson submitted declarations stating his only contact with Chamberlain was as a member of the Federal Circuit panel that affirmed the Court of Federal Claims’ dismissal; all actions were judicial and within his official duties.
- Bryson moved to dismiss; Chamberlain filed a Motion for Mistrial. The District Court considered Bryson’s motion under Rule 12(b)(6).
- The Court dismissed the amended complaint in full for failure to state a plausible claim and because Judge Bryson is entitled to absolute judicial immunity for actions taken in his judicial capacity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the amended complaint states a plausible claim (conspiracy to commit murder) | Chamberlain alleges Bryson colluded with others to inflict bodily harm/murder; seeks money judgment | Bryson argues the complaint lacks factual allegations plausibly showing an agreement or wrongful conduct beyond judicial acts | Dismissed: complaint fails Rule 8/12(b)(6) plausibility requirements for conspiracy allegations |
| Whether Bryson is liable for actions taken in his appellate role | Chamberlain contends Bryson’s appellate actions were part of the alleged conspiracy and actionable | Bryson asserts all contested acts were judicial, within his official duties, and taken in good faith | Dismissed: absolute judicial immunity bars damages for acts within judicial capacity |
Key Cases Cited
- Erickson v. Pardus, 551 U.S. 89 (per curiam) (pleading standard: short and plain statement under Rule 8)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must state a plausible claim)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for factual allegations)
- Patton Boggs LLP v. Chevron Corp., 683 F.3d 397 (D.C. Cir. 2012) (applying Iqbal/Twombly plausibility in D.C. Circuit)
- Forrester v. White, 484 U.S. 219 (judicial immunity doctrine protects judicial independence)
- Mireles v. Waco, 502 U.S. 9 (absolute immunity for judicial acts)
- Neal v. Kelly, 963 F.2d 453 (D.C. Cir. 1992) (procedural notice to pro se litigant regarding unopposed motions)
- Fox v. Strickland, 837 F.2d 507 (D.C. Cir. 1988) (procedural guidance for notices to pro se litigants)