Johnson v. Allegheny County Court of Common Pleas
669 F. App'x 74
| 3rd Cir. | 2016Background
- David Johnson, a prisoner, sued the Allegheny County Court of Common Pleas (ACCCP) and the U.S. District Court for the Western District of Pennsylvania (WDPA), seeking about $1.5 million, alleging constitutional injury from how his post-conviction applications were construed.
- The Magistrate Judge screened the complaint under the Prison Litigation Reform Act (PLRA) and recommended dismissal because the defendant courts are immune from monetary suits.
- Johnson objected, asserting (contrary to his complaint caption) that he had sued individual judges rather than the courts themselves.
- The District Court adopted the Magistrate Judge’s recommendation and dismissed the complaint under 28 U.S.C. § 1915(e)(2)(B)(iii) without leave to amend.
- Johnson appealed; the WDPA moved for summary affirmance. The Third Circuit reviewed immunity de novo and considered whether dismissal under § 1915(e)(2)(B)(iii) was proper.
- The Third Circuit summarily affirmed, holding that both courts (and, alternatively, the judges) were entitled to absolute immunity and that amendment would be futile.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ACCCP and WDPA can be sued for money damages | Johnson sought monetary relief from those courts for alleged constitutional injury | Courts are immune from monetary suits | The courts are entitled to absolute immunity; suit barred |
| Whether individual judges may be sued for rulings adverse to Johnson | Johnson contended he sued particular judges (in objections) for misconstruing his filings | Judges are absolutely immune for judicial acts | Judges would be immune for rulings; suit barred |
| Whether dismissal under § 1915(e)(2)(B)(iii) was proper on immunity grounds | Johnson challenged dismissal | § 1915(e)(2)(B)(iii) permits dismissal when complaint seeks money against immune defendants; validity apparent from complaint | Dismissal was proper; immunity defense was unmistakable from the complaint |
| Whether leave to amend should have been granted | Implied request to amend to name judges or otherwise cure pleading | Amendment would be futile given absolute immunity | Leave to amend denied as futile |
Key Cases Cited
- FDIC v. Meyer, 510 U.S. 471 (federal courts and agencies immune from certain monetary suits)
- P.R. Aqueduct & Sewer Auth. v. Metcalf & Eddy, Inc., 506 U.S. 139 (jurisdictional/sovereign immunity principles)
- Haybarger v. Lawrence Cty. Adult Prob. & Parole, 551 F.3d 193 (application of immunity and PLRA screening)
- Mireles v. Waco, 502 U.S. 9 (judicial immunity for judicial acts)
- Briscoe v. LaHue, 460 U.S. 325 (scope of absolute immunity for judges)
- Grayson v. Mayview State Hosp., 293 F.3d 103 (futility of amendment standard)
- Walker v. Thompson, 288 F.3d 1005 (standards for sua sponte dismissal under § 1915)
- Figueroa v. Blackburn, 208 F.3d 435 (de novo review of absolute immunity)
- Tourscher v. McCullough, 184 F.3d 236 (affirmance may be upheld on any ground supported by the record)
- Ahmed v. Dragovich, 297 F.3d 201 (PLRA applies despite post‑filing release)
- Harris v. City of New York, 607 F.3d 18 (PLRA application despite changed incarceration status)