Michael A. Maps v. Miami Dade Staff Attorney, 693 F. App'x 784

Michael A. Maps, a state inmate, sued Florida Circuit Court Judge Jason E. Bloch and Assistant State Attorney Amanda Newman under 42 U.S.C. § 1983 seeking money damages and release from prison.
Maps alleged Newman charged him by information (not indictment), prosecuted him after the statute of limitations had run (Ex Post Facto Clause claim), and lacked evidence of sexual battery.
Maps alleged Bloch’s “silent action of approval” of Newman’s conduct amounted to a constitutional violation.
A magistrate judge recommended dismissal under 28 U.S.C. § 1915(e)(2)(B)(ii) for failure to state a claim, finding absolute immunity and that injunctive relief (release) was improper under § 1983.
The district court adopted the recommendation; Maps appealed. The Eleventh Circuit reviewed de novo and affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Bloch is immune from § 1983 damages	Bloch lacked jurisdiction and thus acted in the clear absence of all jurisdiction, so no absolute immunity	Bloch acted in his judicial capacity during normal courtroom proceedings, so absolute judicial immunity applies	Court: Bloch entitled to absolute judicial immunity; claims for money damages dismissed
Whether Prosecutor Newman is immune from § 1983 damages	Charging by information, prosecuting after limitations period, and lacking evidence are actionable conduct	Prosecutorial acts challenged were advocacy functions in initiating/prosecuting the case, so absolute prosecutorial immunity applies	Court: Newman entitled to absolute prosecutorial immunity for damages; claims dismissed
Whether Newman can be ordered to release Maps via § 1983 (injunctive relief)	Maps seeks release from prison as injunctive relief under § 1983	Defendants: challenge to fact/duration of confinement must be pursued via habeas or state remedies, not § 1983	Court: § 1983 is improper vehicle for release; dismissal of injunctive relief claims affirmed

Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard: plausible on its face)
Bolin v. Story, 225 F.3d 1234 (absolute immunity for judges and prosecutors explained)
Hart v. Hodges, 587 F.3d 1288 (prosecutorial absolute immunity for advocacy functions)
Rivera v. Leal, 359 F.3d 1350 (limits on prosecutorial immunity when acting as investigator/complaining witness)
Dykes v. Hosemann, 776 F.2d 942 (judge acts "in clear absence of all jurisdiction" when matter is outside court's subject-matter jurisdiction)
Sibley v. Lando, 437 F.3d 1067 (factors for determining whether acts are judicial in nature)
Wilkinson v. Dotson, 544 U.S. 74 (state inmate must use habeas for claims attacking fact/duration of confinement)
Douglas v. Yates, 535 F.3d 1316 (affirmative defenses that bar recovery may justify Rule 12(b)(6) dismissal)