Linda Andrews v. Kathryn Hens-Greco, 641 F. App'x 176

Background

Andrews served as a court-appointed educational/medical guardian in Allegheny County and submitted fee Petitions to judges for payment.
As Presiding Administrative Judge, Hens-Greco required all guardians to submit outstanding Petitions to her by August 30, 2011; Andrews complied but five Petitions needed corrections and were refiled per court instructions.
On April 3, 2012 Judge Hens-Greco wrote that the Petitions would not be paid because they were submitted after the August 30, 2011 deadline.
Andrews sued pro se in federal court alleging violations of the Fourteenth Amendment (due process and equal protection) and the IDEA, seeking money, declaratory relief, and injunctions.
Hens-Greco moved to dismiss based on absolute judicial immunity and Eleventh Amendment immunity; the Magistrate Judge and District Court recommended and entered dismissal with prejudice for failure to state a claim and lack of jurisdiction.
Andrews appealed; the Third Circuit reviewed de novo and affirmed dismissal, concluding judicial immunity and Eleventh Amendment barred money claims and Andrews lacked Article III standing for prospective relief.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether judge is immune from money damages (individual capacity)	Andrews argued Hens‑Greco improperly denied her Petitions and acted beyond proper procedure, so immunity should not apply	Hens‑Greco asserted absolute judicial immunity for judicial acts; denial of fee Petitions is judicial	Held: Absolute judicial immunity applies; denial was a judicial act and not in complete absence of jurisdiction
Whether official-capacity money damages are barred by Eleventh Amendment	Andrews sought money from judge in official capacity for unpaid Petitions	Hens‑Greco argued the claim is effectively against the state/court and barred by Eleventh Amendment	Held: Eleventh Amendment bars official-capacity money damages against a state court judge
Whether declaratory/injunctive relief is available for past-denied Petitions	Andrews sought declaratory relief that the April 3 letter was null and void and asked for payment/return of property	Hens‑Greco argued relief sought was retrospective for past denials and not barred by immunity but not proper because it targets past conduct	Held: Relief relating to already-denied Petitions is retrospective and not available as prospective relief; immunity does not bar, but relief is inappropriate
Whether Andrews has Article III standing for prospective relief on future Petitions	Andrews claimed the April 3 letter chilled her from submitting other Petitions, creating future injury risk	Hens‑Greco argued the letter referred only to past Petitions and gives no real, immediate threat of future denial	Held: No Article III standing; Andrews failed to show a real and immediate threat of future injury

Key Cases Cited

Figueroa v. Blackburn, 208 F.3d 435 (3d Cir. 2000) (explaining absolute judicial immunity rationale)
Mireles v. Waco, 502 U.S. 9 (1991) (defining exceptions to judicial immunity)
Stump v. Sparkman, 435 U.S. 349 (1978) (identifying acts as judicial in nature even if informal)
Gallas v. Supreme Court of Pa., 211 F.3d 760 (3d Cir. 2000) (judge does not act in clear absence of all jurisdiction when order is colorably within court's jurisdiction)
Benn v. First Judicial Dist. of Pa., 426 F.3d 233 (3d Cir. 2005) (Eleventh Amendment immunity applies to state courts)
Jones v. Lilly, 37 F.3d 964 (3d Cir. 1994) (official-capacity suit is against the entity, not the individual)
Blanciak v. Allegheny Ludlum Corp., 77 F.3d 690 (3d Cir. 1996) (retrospective relief addresses past conduct and is not prospective)
Brown v. Fauver, 819 F.2d 395 (3d Cir. 1987) (standing requires real and immediate threat for prospective relief)
City of Los Angeles v. Lyons, 461 U.S. 95 (1983) (no injunctive relief absent established likelihood of future harm)
Alston v. Parker, 363 F.3d 229 (3d Cir. 2004) (denial with prejudice appropriate where amendment would be futile)