Farr v. Riordan
1:25-cv-11706
| E.D. Mich. | Jun 30, 2025Background
- Plaintiff Domonique Farr, currently incarcerated for second-degree murder and felony-firearm, filed a pro se civil rights complaint against Judge Michael Riordan of the Michigan Court of Appeals.
- Farr had previously sought state and federal post-conviction relief, all of which were denied, including a state habeas petition denied by a panel led by Judge Riordan.
- The Complaint alleges that Judge Riordan, in his official capacity, violated Farr’s federal rights by denying the state habeas petition without sufficient legal reasoning.
- The Complaint was filed in forma pauperis and thus subject to mandatory screening under the Prison Litigation Reform Act (PLRA).
- The Court reviewed the Complaint for failure to state a claim, frivolity, and immunity, and ultimately dismissed the case.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Plaintiff stated a viable § 1983 federal claim | Judge Riordan deprived him of federal rights in denying state habeas | None stated (Defendant not served) | No, Complaint fails to allege any deprivation of federal rights |
| Whether Judge Riordan is immune under the Eleventh Amendment | Judge Riordan can be sued in his official capacity | Judge Riordan is a state official, entitled to immunity | Yes, suit barred by Eleventh Amendment where damages sought |
| Whether Plaintiff’s claims are barred by absolute judicial immunity | Judge Riordan acted outside jurisdiction in denying petition | Judge Riordan acted in his judicial capacity | Yes, actions within judicial capacity are absolutely immune |
| Whether defects in state post-conviction procedures create federal liability | Defects in state process violate due process | Defective state process not grounds for § 1983 relief | No, federal law does not provide remedy for such defects |
Key Cases Cited
- Denton v. Hernandez, 504 U.S. 25 (1992) (defining standards for frivolity under PLRA)
- Neitzke v. Williams, 490 U.S. 319 (1989) (defining frivolity in in forma pauperis litigation)
- Haines v. Kerner, 404 U.S. 519 (1972) (liberal pleading standard for pro se litigants)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for sufficient factual matter)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (pleading standard for factual plausibility)
- Parratt v. Taylor, 451 U.S. 527 (1981) (elements of § 1983 claim)
- Will v. Mich. Dep't of State Police, 491 U.S. 58 (1989) (state and state officials immune from § 1983 suit in federal court)