REARDON v. WALKER
1:25-cv-00235
D. Me.Jul 14, 2025Background
- Nathan Reardon, convicted of bank fraud in 2022, received a sentence including a ban on self-employment as part of supervised release.
- After his initial term, Reardon was detained for supervised release violations, including breaking the self-employment ban; his sentence was revoked and a new term imposed with the same conditions.
- On appeal, the First Circuit vacated the self-employment ban, questioning whether it was the least restrictive means, but did not prohibit its reinstatement.
- Judge Walker subsequently re-imposed the self-employment restriction on remand; Reardon again appealed, with that appeal pending at the time of this action.
- Reardon filed this suit pro se, claiming that the judge and probation officers unlawfully enforced a vacated condition of supervised release in violation of his Fifth Amendment rights.
- The court conducted a preliminary review of the complaint under in forma pauperis status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Absolute judicial immunity (Judge Walker) | Judge Walker exceeded authority by enforcing vacated ban | Actions were performed in judicial capacity | Dismissed; judge is absolutely immune |
| Immunity for probation officers | Probation officers acted outside lawful bounds | Actions intimately associated with judicial process | Dismissed; officers are absolutely immune |
| Enforcement of vacated condition | Enforced probation term vacated by appellate court | Ban could be lawfully re-imposed on remand | Dismissed; re-imposition not barred |
| Bivens liability for federal officers | Constitutional violation actionable under Bivens | Immunity doctrine bars suit against these defendants | Dismissed; no Bivens claim due to immunity |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard for sufficient factual matter)
- Erickson v. Pardus, 551 U.S. 89 (liberal pleading standard for pro se litigants)
- Forrester v. White, 484 U.S. 219 (functional approach to judicial immunity)
- Stump v. Sparkman, 435 U.S. 349 (scope of judicial immunity)
- Mireles v. Waco, 502 U.S. 9 (nature and function test for immunity)
- Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (recognized federal constitutional tort claims against federal officers)