Jennifer Foster v. Amanda Fisher
694 F. App'x 887
| 4th Cir. | 2017Background
- Appellant Jennifer Nicole Foster filed a 42 U.S.C. § 1983 suit against Magistrate Amanda Fisher, Chief District Judge Calvin Hill, and others, challenging a contempt finding, her arrest and detention, and related procedures.
- The district court adopted a magistrate judge’s recommendation, granted defendants’ motions to dismiss, and denied Foster’s motion to alter or amend. Foster appealed pro se.
- Foster alleged Fisher committed perjury, unlawfully arrested/convicted her, and used improper bond procedures during detention.
- Foster sought monetary and equitable relief (declaratory relief) against Fisher and supervisory liability against Hill for Fisher’s actions.
- The court considered immunity doctrines (absolute judicial/witness immunity), Rooker–Feldman implications, and standards for supervisory liability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Perjury claim against Fisher | Foster asserted Fisher committed perjury and that this supported a § 1983/private civil action | Perjury does not, by itself, state a § 1983 claim or a private right of action absent a civil-rights violation | Court: Foster failed to show a viable § 1983 claim or private cause of action based on alleged perjury; dismissal affirmed |
| Judicial immunity for Fisher (arrest/detention) | Foster argued Fisher is not immune for actions leading to her arrest/detention | Fisher asserted absolute judicial immunity as a magistrate performing judicial acts (contempt power) | Court: Fisher’s contempt and related acts were judicial and within jurisdictional authority; absolute immunity bars monetary claims |
| Declaratory/equitable relief for alleged illegal arrest/detention | Foster sought declaratory relief that Fisher violated her constitutional rights | Defendants argued equitable relief inappropriate; immunity and lack of justiciable controversy | Court: District court did not abuse discretion denying declaratory relief; Foster failed to show relief would resolve a real controversy |
| Supervisory liability against Chief Judge Hill | Foster claimed Hill is liable for Fisher’s conduct as supervisory official | Hill argued lack of supervisory authority/knowledge and absence of deliberate indifference or causal link | Court: Foster failed to show Hill had supervisory control, knew of a pervasive risk, or acted with deliberate indifference; supervisory claim dismissed |
Key Cases Cited
- King v. Myers, 973 F.2d 354 (4th Cir.) (magistrates entitled to judicial immunity like judges)
- Stump v. Sparkman, 435 U.S. 349 (1978) (judicial immunity applies even if action was erroneous, malicious, or exceeded authority unless acted in clear absence of jurisdiction)
- Timmerman v. Brown, 528 F.2d 811 (4th Cir.) (judicial immunity does not bar equitable relief)
- Wilkins v. Montgomery, 751 F.3d 214 (4th Cir.) (elements for supervisory liability under § 1983)
- Aetna Cas. & Sur. Co. v. Ind-Com Elec. Co., 139 F.3d 419 (4th Cir.) (standard for when declaratory relief is appropriate)
- Dist. of Columbia Ct. App. v. Feldman, 460 U.S. 462 (Rooker–Feldman doctrine referenced)
- Rooker v. Fid. Trust Co., 263 U.S. 413 (Rooker–Feldman doctrine referenced)