Knox v. Bland
2011 U.S. App. LEXIS 2828
| 10th Cir. | 2011Background
- Knox, an inmate in Oklahoma, filed a pro se 42 U.S.C. § 1983 complaint against eight state judges.
- His claims arise from the state court’s denial of his request to change his name for religious reasons to Ali Ishmael Mandingo Warrior Chief.
- He sought mandamus and injunctive relief, asserting violations of multiple constitutional rights and the Religious Land Use and Institutionalized Persons Act.
- The district court dismissed the complaint as frivolous and malicious under 28 U.S.C. § 1915A(b)(1).
- On appeal, Knox challenges the dismissal and seeks reconsideration of the district court’s rulings.
- The panel liberally construes pro se pleadings but concludes relief is unavailable in federal court.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rooker-Feldman bars the claim | Knox argues federal court review of state-court denial is permissible. | Defendants contend Rooker-Feldman abstains the claim as impermissible appellate review. | Rooker-Feldman bars relief. |
| Whether mandamus relief can be issued against state judges | Knox seeks a writ directing judges to act in their capacities. | Mandamus cannot command state judges in their official duties. | No mandamus relief against state judges. |
| Whether injunctive relief against judges is available under § 1983 | Knox seeks an injunction against judges. | Injunctive relief against judicial officers is limited by statute and case law. | Injunctive relief against judges is unavailable here. |
| Whether the district court properly deemed the suit frivolous | Knox disputes the frivolous/malicious characterization and related strikes. | Courtly review supports dismissal as frivolous. | District court properly characterized the suit as frivolous. |
Key Cases Cited
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (U.S. 1923) (establishes abstention principle: state-court losers cannot seek federal review)
- D.C. Court of Appeals v. Feldman, 460 U.S. 462 (U.S. 1983) (extends Rooker-Feldman abstention to denials of federal review of state judgments)
- Johnson v. De Grandy, 512 U.S. 997 (U.S. 1994) (explains limits of Rooker-Feldman and federal-review scope)
- Van Sickle v. Holloway, 791 F.2d 1431 (10th Cir. 1986) (no authority to issue mandamus to a state court judge)
- Olson v. Hart, 965 F.2d 940 (10th Cir. 1992) (federal courts cannot mandamus state judges; related considerations for injunctive relief)
- Harris v. Champion, 51 F.3d 901 (10th Cir. 1995) (injunctive relief against a state officer discussed but abrogated by 1996 Act)
- Pulliam v. Allen, 466 U.S. 522 (U.S. 1984) (policy on monetary liability of judges; immunity considerations)
- Lundahl v. Zimmer, 296 F.3d 936 (10th Cir. 2002) (statutory immunity and damages considerations in § 1983 actions against judges)