892 F. Supp. 2d 209
D.D.C.2012Background
- McIntyre, a DC prisoner, challenges parole denials by the US Parole Commission.
- Parole hearings occurred in 2010 (Kubic) and 2010 (Pacholski) with an upward departure from guidelines.
- Remand after a habeas petition in the Middle District of Pennsylvania challenged the Commission’s departure from 1987 DC Regulations.
- The remand court found no rational basis for admitting alleged admissions at the murders; on remand the Commission again denied parole.
- Plaintiff sues under 42 U.S.C. §1983 and the Privacy Act, naming Commission officials in official and individual capacities.
- Court grants Defendants’ motion to dismiss based on res judicata, quasi-judicial immunity, and failure to state a Privacy Act claim.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether res judicata bars the §1983 claim | Plaintiff argues new theory against named officials. | Defendants contend the habeas judgment precludes this action. | Yes; res judicata bars the §1983 claim. |
| Whether defendants have quasi-judicial immunity | Claims against officials should not be cloaked by immunity. | Officials’ functions are quasi-judicial and insulated from damages. | Yes; defendants are protected by quasi-judicial immunity. |
| Whether Privacy Act claim survives | Defendants relied on inaccurate records to deny parole. | Court should require intentional misconduct; record accuracy not proven. | No; Privacy Act claim fails. |
Key Cases Cited
- Drake v. FAA, 291 F.3d 59 (D.D.C. 2002) (three-factor res judicata test applied here)
- Allen v. McCurry, 449 U.S. 90 (1980) (final judgment on the merits precludes relitigation)
- Youngin’s Auto Body v. Dist. of Columbia, 711 F. Supp. 2d 72 (D.D.C. 2010) (three-part res judicata inquiry applied here)
- Wilson v. Fulwood, 772 F. Supp. 2d 246 (D.D.C. 2011) (privity and res judicata considerations in §1983 actions against parole officials)
- Christian v. McHugh, 847 F. Supp. 2d 68 (D.D.C. 2012) (preclusion of civil actions for habeas petitions challenging military punishment)
- Doe v. Chao, 540 U.S. 614 (2004) (privacy Act damages framework; record maintenance requirement)
- Deters v. U.S. Parole Comm’n, 85 F.3d 655 (D.C. Cir. 1996) (privacy Act damages framework; elements for damages claim)
- Laningham v. U.S. Navy, 813 F.2d 1236 (D.C. Cir. 1987) (intentional or willful violation standard under Privacy Act)