Keller-Bee v. State, 138 A.3d 1253

In April 2010 Keller‑Bee appeared in District Court on a show‑cause order and, according to the court clerk’s later inquiry, did appear as required; the show‑cause was dismissed at that time.
Nine months later a judgment creditor sought a contempt finding and a body attachment for Keller‑Bee; the District Court Administrative Judge signed the body attachment.
On January 27, 2011 the body attachment was executed and Keller‑Bee was arrested and later released the same day; the clerk’s office later informed her she should not have been arrested.
Keller‑Bee sued the State (December 2013), alleging negligence and malfeasance by unnamed District Court clerks who prepared/presented the body‑attachment papers to the judge; she sought damages for wrongful arrest and related harms.
The Circuit Court denied the State’s motion to dismiss based on judicial immunity; the Court of Special Appeals reversed. The Court of Appeals granted certiorari and affirmed the Court of Special Appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether absolute judicial immunity bars Keller‑Bee’s suit against the State for the clerk’s alleged negligence that led to a body attachment	Keller‑Bee: the unnamed clerk negligently prepared/forwarded the file and thus caused the wrongful arrest; clerks should not get blanket immunity	State: the operative proximate cause was the judge’s issuance/signature on the body attachment, a judicial act protected by absolute immunity; any clerk negligence was not the proximate cause	Held: suit barred. The judge’s signing was the proximate cause; absolute judicial immunity applies and the clerk’s conduct was not the proximate cause of injury
Whether immunity should be extended to clerks not supervised/directed by a judge	Keller‑Bee: Maryland law does not automatically extend absolute immunity to all District Court clerks; unnamed clerk lacked supervisory direction and so should be liable	State (alternative): immunity attaches to functions integral to the judicial process regardless of actor; immunity can protect nonjudges performing judicial functions	Held: Court did not decide whether clerks always share judges’ immunity because it was unnecessary; even assuming no extension, the clerk’s acts were not the proximate cause, so dismissal was required

Parker v. State, 337 Md. 271 (1995) (issuance of arrest warrants is a judicial act entitled to absolute immunity)
Forrester v. White, 484 U.S. 219 (1988) (immunity analysis focuses on the nature of the function, not the actor)
Bradley v. Fisher, 80 U.S. 335 (1872) (foundational common‑law doctrine of judicial immunity)
D’Aoust v. Diamond, 424 Md. 549 (2012) (judicial immunity may extend to nonjudicial actors performing integral judicial tasks)
Mireles v. Waco, 502 U.S. 9 (1991) (orders directing officers to bring persons before the court are judicial acts)
Foster v. Walsh, 864 F.2d 416 (6th Cir. 1988) (clerk issuing a warrant at a judge’s direction performs a function to which absolute immunity attaches)