Miguel Perez v. Camden County Municipal Court
714 F. App'x 134
| 3rd Cir. | 2017Background
- Miguel Perez, who is profoundly deaf and uses ASL, was convicted of DUI and required to complete a drivers’ education course; he did not complete it and was summoned to Camden Municipal Court.
- Perez requested an ASL interpreter several weeks before his court date; across eight appearances over a year the court provided an interpreter only once.
- Perez sued Camden Municipal Court and the City of Camden under the ADA, the Rehabilitation Act, and the New Jersey Law Against Discrimination for failing to provide reasonable accommodations.
- The district court granted Perez partial summary judgment on liability under the ADA, the Rehabilitation Act, and the NJLAD; it granted Camden summary judgment on Perez’s requested injunctive relief but denied summary judgment as to damages.
- Camden appealed, arguing (among other things) that judicial immunity should bar the suit and that the district court erred in granting partial summary judgment to Perez.
- The Court of Appeals determined it lacked jurisdiction to hear the appeal and dismissed it.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Appealability / final judgment | Perez: district rulings leave no appealable collateral issue | Camden: denial of judicial immunity or district statement on immunity is immediately appealable under collateral order doctrine | Dismissed for lack of jurisdiction; order not final and collateral-order test not met |
| Collateral order doctrine / third prong (unreviewable loss) | Perez: N/A (argued against appealability) | Camden: denial of immunity would be effectively unreviewable after final judgment | Court: No substantial claim of absolute judicial immunity because no judicial officer was named; interest insufficient for immediate appeal |
| Applicability of judicial immunity to municipal entities | Perez: Immunity applies only to individual judicial officers, not municipalities | Camden: Judicial-immunity-related statements permit immediate review | Held: Judicial immunity protects individual judges; municipal defendants cannot use judicial immunity to obtain interlocutory appeal |
| Reviewability of district court’s statement on immunity | Perez: Statement not appealable | Camden: Statement is conclusive and separable from merits | Held: Statement is not an appealable collateral order; appeal dismissed |
Key Cases Cited
- Riley v. Kennedy, 553 U.S. 406 (U.S. 2008) (final-judgment rule and when an order is final)
- Cohen v. Beneficial Industrial Loan Corp., 337 U.S. 541 (U.S. 1949) (collateral order doctrine)
- Digital Equipment Corp. v. Desktop Direct, Inc., 511 U.S. 863 (U.S. 1994) (three-part test for collateral order doctrine)
- Mitchell v. Forsyth, 472 U.S. 511 (U.S. 1985) (denial of substantial claim of absolute immunity is immediately appealable)
- Stump v. Sparkman, 435 U.S. 349 (U.S. 1978) (scope of judicial immunity)
- Bradley v. Fisher, 80 U.S. (13 Wall.) 335 (U.S. 1872) (rationale for judicial immunity)
- Brown v. Grabowski, 922 F.2d 1097 (3d Cir. 1990) (municipal defendants cannot use individual official immunities to obtain interlocutory review)
- Venen v. Sweet, 758 F.2d 117 (3d Cir. 1985) (denial of judicial immunity on motion to dismiss is appealable under collateral order doctrine)