Jackson v. Ramirez, 691 F. App'x 45

Roberto Jackson, pro se, sued parole officers, an ALJ (Amy Porter), and private mental-health providers alleging violations of First Amendment, procedural and substantive due process, HIPAA, and NY confidentiality laws after parole revocation proceedings.
Core factual allegations: therapist Maria Dimeo reported Jackson missed appointments, a bipolar diagnosis, medication, and allegedly told parole officer Angie Ramirez that Jackson threatened her; Ramirez is alleged to have forged the report, leading to Jackson’s arrest for parole violation.
Jackson challenged ALJ Porter’s impartiality at the parole-revocation hearing and sought monetary damages from state officials in their official capacities and confidentiality breaches by Dimeo.
District court dismissed the complaint under Fed. R. Civ. P. 12(b)(6); Jackson appealed only three issues: procedural due process claim against ALJ Porter, official-capacity damages against state defendants, and breach-of-confidentiality claims against Dimeo.
The Second Circuit reviewed de novo and affirmed the dismissal in all respects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ Porter is immune from monetary damages for alleged bias in parole hearing	Jackson: Porter acted with bias denying procedural due process	Porter: Entitled to absolute/quasi-judicial immunity for adjudicative acts	Court: Dismissed — quasi-judicial/judicial immunity applies
Whether state officials in official capacity can be sued for damages	Jackson: Seeks monetary relief from state officials	Defendants: Eleventh Amendment bars suits against states and officials in official capacity	Court: Dismissed — Eleventh Amendment bars the claims
Whether Dimeo’s disclosure violated substantive due process	Jackson: Disclosure of missed appointments, diagnosis, meds was unlawful and conscience-shocking	Dimeo: Disclosure was permitted/conditioned by parole consent; not conscience-shocking	Court: Dismissed — conduct not conscience-shocking; substantive due process fails
Whether HIPAA or state law supplies private causes of action	Jackson: Claims under HIPAA and state confidentiality law	Defendants: HIPAA does not create private right; district court may decline supplemental jurisdiction on state claims	Court: Dismissed — Jackson abandoned HIPAA argument on appeal; district court properly declined supplemental jurisdiction for state claims

Chambers v. Time Warner, 282 F.3d 147 (2d Cir. 2002) (standard for Rule 12(b)(6) review)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility pleading standard)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions not entitled to assumption of truth)
Bliven v. Hunt, 579 F.3d 204 (2d Cir. 2009) (judicial immunity principles)
Butz v. Economou, 438 U.S. 478 (1978) (quasi-judicial immunity for judge-like functions)
Montero v. Travis, 171 F.3d 757 (2d Cir. 1999) (parole-board officials entitled to absolute immunity for quasi-adjudicative acts)
CSX Transp., Inc. v. N.Y. State Office of Real Prop. Servs., 306 F.3d 87 (2d Cir. 2002) (Eleventh Amendment sovereign immunity principles)
Davis v. New York, 316 F.3d 93 (2d Cir. 2002) (official-capacity suits as suits against the state)
Trotman v. Palisades Interstate Park Comm’n, 557 F.2d 35 (2d Cir. 1977) (state waiver of immunity analysis)
Dube v. State Univ. of N.Y., 900 F.2d 588 (2d Cir. 1990) (Congressional abrogation of state immunity analysis)
O’Connor v. Pierson, 426 F.3d 187 (2d Cir. 2005) (substantive due process requires conscience-shocking conduct)
LoSacco v. City of Middletown, 71 F.3d 88 (2d Cir. 1995) (abandonment of issues not argued on appeal)
Kolari v. N.Y.-Presbyterian Hosp., 455 F.3d 118 (2d Cir. 2006) (district court discretion to decline supplemental jurisdiction)