Olson v. Yang, 1:25-cv-00653

Timothy Luther Olson, a prisoner at Milwaukee County Jail, filed a pro se 42 U.S.C. § 1983 complaint against Judge Kristy Yang and two state public defenders.
Olson alleged Judge Yang and the public defenders improperly conspired to appoint specific counsel to his ongoing state criminal case.
This is Olson’s third similar lawsuit against these defendants regarding their conduct in his criminal proceeding.
The court screened the complaint pursuant to the Prison Litigation Reform Act (PLRA) and allowed Olson to proceed without prepaying the filing fee.
Olson sought monetary damages for what he alleged was a corrupt and malicious appointment of a public defender.
The court dismissed the complaint as both frivolous and for failure to state a claim; noted dismissal was also due to duplicative litigation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are state public defenders state actors?	Public defenders conspiring with judge	Public defenders not state actors	Not state actors under §1983
Is judge immune for judicial acts?	Judge acted corruptly in appointment	Acts within judicial capacity immune	Judge has absolute immunity
Duplicative litigation	New claims based on ongoing conduct	Already litigated same claims	Case dismissed as duplicative
Frivolousness of claim	Allegations show statutory violation	No actionable claim under §1983	Dismissed as frivolous and failed to state

Polk Cnty. v. Dodson, 454 U.S. 312 (Public defenders are not state actors under §1983)
Polzin v. Gage, 636 F.3d 834 (Judges have absolute immunity for acts within judicial capacity)
Dellenbach v. Letsinger, 889 F.2d 755 (Judicial immunity applies even to acts done maliciously or corruptly)
Rowe v. Shake, 196 F.3d 778 (District courts may screen complaints regardless of fee status)