Savoie v. Martin
2012 U.S. App. LEXIS 4579
6th Cir.2012Background
- Savoie filed for divorce in Williamson County, Tennessee, with Judge Martin later mediating the case as part of his private practice for Stites & Harbison.
- Martin became a Tennessee judge on January 1, 2009, after completing mediation; the March 30 hearing involved a petition to modify a parenting plan and a potential restraining order.
- The court allowed travel to Japan during summers; Savoie feared abduction and sought a TRO, which was initially granted and later lifted at the March 30 hearing.
- After further mediation in May 2009 (not involving Martin), the parenting plan was modified; in August 2009, the ex-wife left the United States with the children and did not return.
- Savoie filed suit in 2010 against Martin (individual and official capacities), Stites & Harbison, and a court-ordered parental coordinator, asserting §1983 and state-law claims; the district court dismissed these claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Martin's conduct at the March 30 hearing is protected by judicial immunity | Savoie argues immunity does not cover coercive or biased actions during the hearing. | Martin contends actions were within judicial function and jurisdiction; immunity applies. | Martin was entitled to judicial immunity for the March 30 hearing. |
| Whether Stites & Harbison can be liable under §1983 for Martin's actions | Savoie asserts vicarious liability or policy-based liability through the employer. | Stites & Harbison cannot be liable under §1983 via respondeat superior or vicarious liability; must show policy causing violation. | District court did not err; Stites & Harbison cannot be liable under §1983 for Martin's actions. |
| Whether Savoie stated a viable §1983 claim against Stites & Harbison based on training or policy | Savoie contends failure to train mediators amounted to a moving- force behind the violation. | Plaintiff failed to plead a policy or deliberate indifference; training adequacy was not shown beyond statutory rule. | No viable §1983 claim against Stites & Harbison; no policy or deliberate indifference shown. |
| Whether declaratory or injunctive relief was properly denied | Savoie seeks declarations about Rule 31 jurisdiction, litigant rights, and child-removal protections. | The district court correctly declined because the state proceedings have concluded and declaratory relief is inappropriate. | Declaratory and injunctive relief properly declined. |
Key Cases Cited
- Mireles v. Waco, 502 U.S. 9 (U.S. 1991) (judicial immunity protected absent complete lack of jurisdiction)
- Stump v. Sparkman, 435 U.S. 349 (U.S. 1978) (immunity remains despite error or excess of authority)
- Street v. Corrections Corp. of Am., 102 F.3d 810 (6th Cir. 1996) (private contractors and state-actor liability; no respondeat superior for §1983)
- Grand Trunk Western R.R. Co. v. Consolidated Rail Corp., 746 F.2d 323 (6th Cir. 1984) (five-factor test for declaratory judgments)
- Miller v. Sanilac Cnty., 606 F.3d 240 (6th Cir. 2010) (deliberate indifference standard for municipal training claims under §1983)
- Fisher v. Harden, 398 F.3d 837 (6th Cir. 2005) (deliberate indifference framework for training claims)
- Montero v. Travis, 171 F.3d 757 (2d Cir. 1999) (injunctive relief against judicial officers limitations under §1983)