Noah F. Corbitt v. Lisa Godbey Wood, 677 F. App'x 596

In 2015 Corbitt, a Georgia state prisoner proceeding pro se and in forma pauperis, sued U.S. District Judge Lisa Godbey Wood under 42 U.S.C. § 1983 alleging she relied on false statements in denying his 28 U.S.C. § 2254 habeas petition.
Corbitt alleged two false statements: (1) Judge Wood claimed to have conducted a de novo review despite the Attorney General declining to file transcripts; (2) Judge Wood stated Corbitt admitted the state court ruled on the merits.
Corbitt sought reopening of his § 2254 proceeding and an order directing Warden Marty Allen/Georgia OAG to file a complete record and explain the alleged false statements.
A magistrate judge recommended dismissal with prejudice as frivolous, denial of leave to amend, and that the dismissal count as a § 1915(g) strike; the district court adopted the R&R.
On appeal Corbitt largely reasserted his habeas-related allegations but did not meaningfully contest the district court’s finding of frivolity. The Eleventh Circuit affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal under 28 U.S.C. § 1915(e)(2)(B)(i) was an abuse of discretion	Corbitt contended Judge Wood relied on false statements and asked to reopen his habeas case	District court found the complaint frivolous and subject to dismissal; argued immunity and improper vehicle	Affirmed: dismissal not an abuse of discretion; complaint frivolous or improper vehicle
Proper defendant/claim framework (§ 1983 vs Bivens)	Corbitt sued under § 1983 a federal judge	Court noted claims against federal officers belong under Bivens, not § 1983	Court observed Bivens is the proper analogue but dismissal still proper
Availability of injunctive relief against a federal judge for reopening habeas proceeding	Corbitt sought injunctive relief to reopen § 2254 and compel filing of records	Defendants argued federal judges have absolute immunity from such relief	Held: absolute judicial immunity bars injunctive relief; claim fails
Whether amendment should have been allowed and whether action counts as a § 1915(g) strike	Corbitt requested reconsideration/reopening; implied request to proceed	District court declined amendment, treating dismissal with prejudice and counting as a strike	Held: denial to amend not error (amendment would be futile); strike properly counted

Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (creates remedy against federal officers analogous to § 1983)
Bilal v. Driver, 251 F.3d 1346 (defines frivolous as lacking arguable merit in law or fact)
Hughes v. Lott, 350 F.3d 1157 (standard of review for § 1915(e)(2)(B)(i) dismissals)
Moreland v. Wharton, 899 F.2d 1168 (frivolous suit guidance)
Kelly v. Serna, 87 F.3d 1235 (apply § 1983 law to Bivens cases)
Bolin v. Story, 225 F.3d 1234 (federal judges absolutely immune from injunctive relief and damages)
Bryant v. Dupree, 252 F.3d 1161 (no need to permit amendment when amendment would be futile)
Timson v. Sampson, 518 F.3d 870 (issues not briefed on appeal by pro se litigants are deemed abandoned)
Abella v. Rubino, 63 F.3d 1063 (claims that would imply invalidity of custody are not cognizable in § 1983/Bivens)