Holtzclaw v. Coggins, 6:25-cv-03974

Plaintiff Weldon Eugene Holtzclaw, Jr., an inmate at Greenville County Detention Center, filed a pro se § 1983 suit against U.S. District Judge Donald C. Coggins, Jr.
Holtzclaw alleged that Judge Coggins violated his constitutional rights by making adverse rulings, closing his cases while appeals were pending, and allegedly committing perjury.
Plaintiff sought monetary damages and injunctive relief, including the tolling of all case deadlines due to his incarceration.
The action was screened under 28 U.S.C. § 1915, which allows dismissal if a complaint is deemed frivolous or seeks relief from an immune defendant.
The court noted Holtzclaw's status as a frequent, vexatious filer subject to prefiling restrictions based on abusive litigation history.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Judicial immunity of Judge Coggins	Coggins acted improperly and violated rights	Judge is immune for acts	Coggins has absolute immunity
Frivolousness of claims	Alleged rights violations and improper acts	Claims baseless	Claims are frivolous, dismissed
Amending complaint	No argument presented	Not addressed	Amendment would be futile
Injunctive relief & case tolling	Incapacity due to incarceration	Not addressed	Relief denied/dismissed

Mireles v. Waco, 502 U.S. 9 (1991) (judges are absolutely immune from damages for judicial acts unless acting without jurisdiction)
Stump v. Sparkman, 435 U.S. 349 (1978) (judicial immunity applies even to allegedly erroneous or malicious acts)
Mitchell v. Forsyth, 472 U.S. 511 (1985) (absolute immunity is immunity from suit, not just from ultimate liability)
Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints construed liberally, but must state a plausible claim)
Weller v. Dep’t of Soc. Servs., 901 F.2d 387 (4th Cir. 1990) (court cannot ignore fundamental pleading deficiencies in pro se actions)