Jiggetts v. Motz, 1:17-cv-01712

Pro se plaintiff Alexander Jiggetts filed a civil-rights complaint seeking to stop the repeated assignment of his cases to Judge J. Frederick Motz and requesting an injunction barring Motz from handling his matters.
Jiggetts alleged most of his many prior filings in the district were assigned to Judge Motz, who dismissed them or ruled for state defendants; some dismissal orders contained allegedly offensive comments about Jiggetts’ mental state.
He claimed the assignment practice amounted to discrimination and even "a form of slavery," and sought explanation of the court’s assignment policy but did not seek monetary damages.
The complaint named Judge Motz, Chief Judge Catherine Blake, Clerk Felicia Cannon, and the U.S. Government; Jiggetts sought recusal of Motz and wider changes to judge assignment.
The court granted in forma pauperis status but reviewed the complaint under 28 U.S.C. § 1915(e)(2)(B) for frivolousness and failure to state a claim.
The court dismissed the complaint, holding (inter alia) that case assignment does not implicate the Eighth Amendment or constitute slavery, recusal is not warranted on disagreement with rulings, and judicial immunity bars damages for judicial acts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Improper assignment / recusal	Motz is repeatedly assigned and "always sides with the state," so must be barred from Jiggetts' cases	Assignment is administrative; disagreement with rulings is not proof of bias	Denied — plaintiff may move for recusal with a legitimate extrajudicial-bias basis; disagreement alone is not grounds for recusal
Constitutional claim (Eighth Amendment / "slavery")	Assignment practice and offensive comments violate the Eighth Amendment and amount to "slavery"	Administrative assignment does not implicate Eighth Amendment and the slavery claim is baseless	Dismissed — assignment does not state an Eighth Amendment or slavery claim
Offensive judicial comments / damages	Comments about mental status are actionable harm	Judicial acts and statements are protected by judicial immunity	Dismissed — judicial immunity bars civil damages for judicial acts taken in judicial capacity
Procedural screening under IFP statute	Complaint filed with IFP status	Court must dismiss frivolous or non‑cognizable claims under §1915(e)(2)(B)	Dismissed for failure to state a claim as permitted by §1915 screening

Erickson v. Pardus, 551 U.S. 89 (lenient pleading standard for pro se complaints)
Bell Atl. Corp. v. Twombly, 550 U.S. 544 (pleading must state plausible claim)
Weller v. Dep’t of Soc. Servs., 901 F.2d 387 (pro se complaints afforded liberal construction)
Beaudett v. City of Hampton, 775 F.2d 1274 (district court may not invent claims for pro se plaintiffs)
White v. White, 886 F.2d 721 (pro se complaints held to less stringent standards)
Shaw v. Martin, 733 F.2d 304 (bias must stem from extrajudicial source to require recusal)
Rippo v. Baker, 137 S. Ct. 905 (due process may require recusal when probability of bias is intolerable)
Williams v. Pennsylvania, 136 S. Ct. 1899 (recusal standard where impartiality might reasonably be questioned)
Mireles v. Waco, 502 U.S. 9 (judicial immunity protects judges from damages for judicial acts)
Stump v. Sparkman, 435 U.S. 349 (absolute judicial immunity for judicial acts within jurisdiction)
Pierson v. Ray, 386 U.S. 547 (rationale for judicial immunity)
Dean v. Shirer, 547 F.2d 227 (judges not liable for exercising judicial authority)