Cinotti v. Adelman
709 F. App'x 39
| 2d Cir. | 2017Background
- Lucia Cinotti, pro se, sued a Connecticut state court judge after adverse rulings in her divorce: denial of motions to compel payment of $50,500 and an order to vacate the marital home.
- Cinotti alleged gender and pro se status discrimination, invoking Title VII in her complaint.
- The district court dismissed, holding (1) Title VII did not provide federal-question jurisdiction and (2) Eleventh Amendment sovereign immunity barred the suit.
- On appeal, the Second Circuit reviewed de novo and construed pro se pleadings liberally.
- The panel concluded the complaint should have been read to raise claims under 42 U.S.C. § 1983 (due process and equal protection) but affirmed dismissal on other grounds.
- The court held injunctive relief barred by § 1983’s limitation for judicial acts, official-capacity monetary claims fail because the judge is not a “person,” and individual-capacity claims fail due to judicial immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Title VII supports federal-question jurisdiction | Cinotti asserted Title VII discrimination by the judge | Judge argued Title VII is inapplicable to a judicial decision in a divorce case | Title VII is inapplicable; does not supply jurisdiction |
| Whether complaint should be construed as asserting § 1983 claims | Cinotti alleged constitutional violations (due process/equal protection) though not citing § 1983 in the complaint | Judge argued lack of federal-question jurisdiction | Court: Liberally construe pro se pleadings; § 1983 claims exist, so federal question jurisdiction applies |
| Whether injunctive relief against the judge is available under § 1983 | Cinotti sought injunctive relief to undo judge’s orders | Judge invoked § 1983’s limitation on injunctive relief for judicial acts | Dismissed: § 1983 bars injunctive relief against judicial officers for judicial acts unless a declaratory decree was violated or declaratory relief was unavailable |
| Whether monetary damages are recoverable against the judge | Cinotti sought money damages (official and individual capacity) | Judge argued (official-capacity) not a "person" under § 1983; (individual-capacity) entitled to judicial immunity | Dismissed: Official-capacity claims fail (not a § 1983 "person"); Individual-capacity claims barred by judicial immunity |
Key Cases Cited
- Capital Mgmt. Select Fund Ltd. v. Bennett, 680 F.3d 214 (2d Cir. 2012) (standard for reviewing a Rule 12(b)(6) dismissal)
- McEachin v. McGuinnis, 357 F.3d 197 (2d Cir. 2004) (pro se pleadings alleging civil-rights violations must be liberally construed)
- Leon v. Murphy, 988 F.2d 303 (2d Cir. 1993) (appellate affirmance may be based on any correct ground supported by the record)
- Washington v. County of Rockland, 373 F.3d 310 (2d Cir. 2004) (elements of a § 1983 claim)
- Will v. Michigan Dep't of State Police, 491 U.S. 58 (1989) (state officials sued in official capacity are not "persons" under § 1983 for monetary relief)
- Mireles v. Waco, 502 U.S. 9 (1991) (judicial immunity protects judges from damages for judicial acts)
- Stump v. Sparkman, 435 U.S. 349 (1978) (judicial immunity applies even if action was erroneous, malicious, or in excess of authority)