Martinez v. Stivers
5:17-cv-00166
W.D. Ky.Dec 8, 2017Background
- Pro se prisoner Leonel Martinez, incarcerated at Kentucky State Penitentiary, sued U.S. District Judge Greg N. Stivers and Kentucky Justice & Public Safety Cabinet attorney Linda Keeton in their individual capacities alleging racial discrimination and denial of lawsuits filed by Hispanic and Black inmates (events dated 2013–2017).
- Martinez sought injunctive relief: an order preventing Judge Stivers from reviewing Hispanic and Black inmates’ lawsuits.
- Martinez had multiple prior § 1983 suits in the same district, including Martinez v. Hiland et al., in which Judge Stivers granted summary judgment for defendants on constitutional claims (including alleged race-based denial of medical treatment).
- The court screened the complaint under 28 U.S.C. § 1915A because Martinez is a prisoner proceeding in forma pauperis.
- The complaint made no factual allegations against Keeton and principally accused Judge Stivers of discriminatory judicial action without alleging that any declaratory decree was violated or declaratory relief was unavailable.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Judicial immunity | Stivers denied Martinez’s and other minority inmates’ lawsuits based on race | Judicial acts by a judge are protected by absolute judicial immunity | Judge Stivers is immune; suit dismissed against him |
| Availability of injunctive relief under § 1983 | Requests injunctive relief barring Stivers from reviewing Hispanic/Black lawsuits | Injunctive relief against judicial officers for judicial acts is barred absent a violated declaratory decree or unavailability of declaratory relief | Injunctive relief barred by § 1983 amendments; claim dismissed |
| Failure to plead against Keeton | Implied claim of participation in racial discrimination | No factual allegations or basis pleaded against Keeton | Claims against Keeton dismissed for failure to state a claim under Rule 8 |
| Screening under § 1915A (failure to state a claim) | Complaint alleges equal protection violations generally | Complaint lacks sufficient factual allegations to state a plausible claim and raises immunity defenses | Complaint dismissed pursuant to 28 U.S.C. § 1915A(b)(1) for failure to state a claim |
Key Cases Cited
- Mireles v. Waco, 502 U.S. 9 (1991) (judicial immunity protects judges for acts within their judicial capacity)
- Forrester v. White, 484 U.S. 219 (1988) (limits to judicial immunity for nonjudicial acts)
- Dennis v. Sparks, 449 U.S. 24 (1980) (principles related to immunity from suit for judges and related issues)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (complaint must contain sufficient factual matter to state a plausible claim)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (plausibility standard for pleadings)
- Erickson v. Pardus, 551 U.S. 89 (2007) (pro se complaints are to be liberally construed)
- Estelle v. Gamble, 429 U.S. 97 (1976) (pro se standards and civil rights pleading principles)
- Stump v. Sparkman, 435 U.S. 349 (1978) (judicial immunity applies to acts within jurisdiction)
- McGore v. Wrigglesworth, 114 F.3d 601 (6th Cir. 1997) (standards for screening prisoner suits under § 1915A)
- Savoie v. Martin, 673 F.3d 488 (6th Cir. 2012) (injunctive relief limitations against judicial officers under § 1983)
- Montero v. Travis, 171 F.3d 757 (2d Cir. 1999) (injunctive relief against judges for judicial acts is generally barred)