486 F. App'x 227
3rd Cir.2012Background
- Coulter pleaded nolo contendere to aggravated assault of her minor daughter; sentence 15–30 months with 36 months probation.
- A no-contact-with-daughter condition was imposed on probation by the trial court in 2010 after Commonwealth motion.
- Superior Court affirmed the no-contact order; parental rights later terminated in 2011; termination affirmed by Superior Court.
- Coulter filed a pro se 42 U.S.C. § 1983 action in 2011 against Judge Doerr, asserting lack of jurisdiction and violation of parental rights.
- District Court dismissed on Rule 12(b)(6) grounds, holding Judge Doerr had absolute judicial immunity from damages.
- This appeal challenges the dismissal and seeks sanctions, venue change, and ongoing relief related to Doerr’s actions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Doerr is absolutely immune from damages in § 1983 suit | Coulter contends immunity does not apply due to corrupt/extra-judicial conduct | Doerr asserts absolute judicial immunity for acts in his official judicial capacity | Yes; immunity applies, dismissal proper |
| Whether Doerr acted outside his jurisdiction to remove immunity | Actions were outside judicial authority in September 2009 dependency matter | Actions were within judicial capacity and jurisdiction; not outside jurisdiction | No; not outside jurisdiction |
| Whether injunctive relief is available against a judge operating in judicial capacity | Seeks injunctive relief to address ongoing impact on parental rights | Section 1983 injunctive relief is generally unavailable against judges acting in their judicial capacity | Barred; injunctive relief not available |
Key Cases Cited
- Mireles v. Waco, 502 U.S. 9 (1991) (absolute immunity for judicial acts)
- Stump v. Sparkman, 435 U.S. 349 (1978) (not limited by bad motives; jurisdiction standard for immunity)
- Bradley v. Fisher, 13 Wall. 335 (1872) (clarifies immunity applies even with error or excess of authority)
- Azubuko v. Royal, 443 F.3d 302 (3d Cir. 2006) (injunctive relief against judges in judicial capacity is barred)
- In re Rockefeller Ctr. Props., Inc. Sec. Litig., 184 F.3d 280 (3d Cir. 1999) (narrow exceptions for documents integral to complaint in dismissal standard)
- Pension Benefit Guar. Corp. v. White Consol. Indus., Inc., 998 F.2d 1192 (3d Cir. 1993) (admissibility of attached documents in Rule 12(b)(6) context)