Rickey Coleman v. Earl Dunlap
695 F.3d 650
7th Cir.2012Background
- Coleman was fired from the Cook County Juvenile Temporary Detention Center in 2007, claiming politics—not budget cuts—drove the decision and a later nonrehire.
- Dunlap was appointed Transitional Administrator in 2007 under a 2002 settlement order with immunity language.
- The 2002 settlement concerned prison conditions and granted Dunlap broad supervisory authority over Center operations.
- Coleman sued under 42 U.S.C. §1983 and also invoked the Shakman consent decrees for patronage redress.
- The district court held Dunlap lacked absolute immunity here and distinguished administrative from judicial acts; Dunlap appealed on immunity.
- The court applied Forrester v. White to evaluate whether Dunlap’s administrative acts were protected by absolute immunity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Dunlap is entitled to absolute immunity for administrative acts | Coleman argues immunity does not cover Dunlap’s employment decisions. | Dunlap contends he acted as a judge’s substitute with absolute immunity. | No absolute immunity for administrative acts; immunity denied on merits. |
| Whether receivership-based immunity applies to Dunlap | Coleman contends immunity should flow from court-ordered control. | Dunlap relies on receivership immunity from administrative acts. | Receivership immunity does not extend to Dunlap’s administrative employment decisions. |
| Whether Forrester controls scope of immunity here | Coleman invokes Forrester to limit immunity to adjudicative acts only. | Dunlap argues some immunity should apply due to supervisory role. | Forrester applies; administrative acts are not protected by absolute immunity. |
Key Cases Cited
- Forrester v. White, 484 U.S. 219 (1988) (judicial immunity limits administrative acts; firing is administrative)
- Stump v. Sparkman, 435 U.S. 349 (1978) (context for judicial capacity vs. administrative action)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (limits on vicarious liability; pleading standards)
- Malley v. Briggs, 475 U.S. 335 (1986) (immunity only as needed to protect judicial actions; not broader)
- Richman v. Sheahan, 270 F.3d 430 (7th Cir. 2001) (immunity protects only ends of a judicial order, not means)