Justice Network Inc v. Craighead County
931 F.3d 753
| 8th Cir. | 2019Background
- TJN, a private probation-service company, contracted with misdemeanor probationers in Craighead County to provide supervision and classes and collected monthly fees under court-ordered fee agreements.
- For nearly 20 years city and county courts collected fees from probationers and forwarded them to TJN; TJN employed 12 local staff in Jonesboro.
- After election, Judges Boling and Fowler announced opposition to privatized probation and in early 2017 implemented an "Amnesty Program": they dismissed or modified probation orders, struck or forgave fees owed to TJN, and allowed reset payment plans and "jail credit."
- TJN sued under 42 U.S.C. § 1983 asserting Contracts Clause and Takings Clause violations and sought damages, declaratory relief, and an injunction against the judges, Craighead County, and several cities. Defendants moved to dismiss under Rule 12(b)(6).
- The district court dismissed: (1) damages claims against the judges based on absolute judicial immunity; (2) injunctive relief as barred by § 1983 amendments absent a violated or unavailable declaratory decree; (3) municipal liability because the judges were state, not municipal, officials. The Eighth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether judges’ acts (ending TJN’s use, forgiving fees) are judicial (immunity for damages) | Acts were administrative/policy decisions not protected by judicial immunity | Acts were judicial modifications/dismissals of probation orders within statutory court powers | Held: Acts were judicial in nature and within jurisdiction; judges entitled to absolute immunity for damages |
| Whether injunctive relief against judges is available | Injunctive relief permissible because actions were enforcement/administrative | Judicial immunity (and § 1983 amendment) bars injunctive relief absent a declaratory decree violation or unavailability | Held: § 1983 bars injunctive relief here; TJN did not allege a violated or unavailable declaratory decree |
| Whether declaratory relief is available post-amendment to § 1983 | Declaratory relief is available to vindicate rights and to permit injunction | Amendment limits relief; declaratory relief should be prospective only | Held: Complaint sought retrospective relief (invalidate past actions); prospective declaratory relief unavailable, so § 1983 relief fails |
| Whether municipal liability attaches to Craighead County and Cities for judges’ actions | Judges were municipal policymakers; their policy should be imputed to municipalities under Monell | Judges are state district court judges (state employees); actions not attributable to county or cities | Held: Judges are state officials (per Arkansas statutes); municipal defendants not liable under Monell |
Key Cases Cited
- Mireles v. Waco, 502 U.S. 9 (1991) (judicial immunity is immunity from suit except for nonjudicial acts or acts in complete absence of jurisdiction)
- Stump v. Sparkman, 435 U.S. 349 (1978) (test for whether an act is ‘judicial’ focuses on the nature and function of the act)
- Monell v. Dep’t of Soc. Servs. of City of N.Y., 436 U.S. 658 (1978) (municipal liability under § 1983 requires a municipal policy or custom causing the constitutional violation)
- Pulliam v. Allen, 466 U.S. 522 (1984) (injunctive relief against judges was available pre-amendment; later abrogated by Congress’s § 1983 amendment)
- Forrester v. White, 484 U.S. 219 (1988) (hiring/firing court personnel are administrative acts not protected by absolute judicial immunity)
- Schottel v. Young, 687 F.3d 370 (8th Cir. 2012) (discussing scope of judicial immunity and its exceptions)
- Martin v. Hendren, 127 F.3d 720 (8th Cir. 1997) (affirming judges’ absolute immunity when acting in judicial capacity)
- Evans v. City of Helena-West Helena, Ark., 912 F.3d 1145 (8th Cir. 2019) (analyzing whether court officials are municipal employees for Monell purposes)