Shuler v. South Carolina, State of
5:19-cv-01015
| D.S.C. | May 31, 2019Background
- Shuler, proceeding pro se and in forma pauperis, sued the State of South Carolina, Orangeburg County sheriff’s officials, magistrates, a circuit judge, and court clerks alleging constitutional violations, FOIA violations, and state torts arising from her 2016 domestic-violence criminal prosecution.
- Core factual allegations: magistrates and clerks refused or delayed giving her case documents (including a 911 call and jury-selection materials), denied discovery, rejected filings, and took actions related to bond, sentencing, appeals, and contempt/show-cause proceedings. She also alleges harassment/retaliation when she criticized a magistrate in the clerk’s office.
- Shuler seeks damages and raises numerous claims regarding pretrial and post-trial errors (Brady, due process, denial of jury trial/speedy trial, jurisdictional objections, recusal, and FOIA violations).
- The magistrate judge screened the complaint under 28 U.S.C. § 1915 and found several legal deficiencies: sovereign immunity for the State, absolute (and quasi-judicial) immunity for judges and court staff, and failure to plead a Brady/due-process violation against sheriff’s personnel.
- The court ordered Shuler to file an amended complaint within 21 days curing the deficiencies or risk recommended dismissal under § 1915.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sovereign immunity of State of South Carolina | Shuler sued the State and seeks damages for constitutional and tort claims. | The State is immune from suit under the Eleventh Amendment and has not consented to suit in federal court. | The State is immune; claims for damages against the State (and official-capacity claims) are barred. |
| Absolute/quasi-judicial immunity for judges and clerks | Shuler alleges magistrates and a circuit judge acted improperly, maliciously, and outside jurisdiction; clerks denied filings and withheld records. | Judicial actors and court personnel performing judicial functions are absolutely (or quasi-) immune from damages claims. | Judges (Daily, Dash, Goodstein) are entitled to absolute judicial immunity; clerks (Sumpter, Clark) have derivative/quasi-judicial immunity. Claims against them for damages are barred. |
| Brady/due-process claim vs. sheriff and deputy | Shuler contends Sheriff Ravenell and Captain Turkvant withheld exculpatory materials (e.g., 911 call) and thus violated due process. | To state a § 1983 Brady claim, plaintiff must allege the evidence was favorable/exculpatory, was suppressed in bad faith (by officers), and caused prejudice; mere refusal to copy or incomplete production is insufficient. | Shuler failed to allege suppression of exculpatory evidence or bad faith; her § 1983 due-process/Brady claim is insufficiently pleaded. |
| Sufficiency and remedy (screening under § 1915) | Shuler seeks to proceed on the pleadings as filed. | Court may dismiss frivolous or insufficient in forma pauperis filings unless amended to cure defects. | Complaint is subject to summary dismissal for failure to state a claim and immunity barriers; Shuler granted leave to amend within 21 days to cure defects. |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standard; legal conclusions not entitled to be assumed true)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
- Erickson v. Pardus, 551 U.S. 89 (liberal construction of pro se complaints)
- Alden v. Maine, 527 U.S. 706 (states’ sovereign immunity from suit in their own courts)
- Seminole Tribe of Fla. v. Florida, 517 U.S. 44 (limitations on Congress’s abrogation of state sovereign immunity)
- Hans v. Louisiana, 134 U.S. 1 (Eleventh Amendment principles)
- Pennhurst State Sch. & Hosp. v. Halderman, 465 U.S. 89 (state agencies/arms of the state and immunity)
- Will v. Michigan Dep’t of State Police, 491 U.S. 58 (state officials in their official capacities are not "persons" under § 1983)
- Quern v. Jordan, 440 U.S. 332 (Congress did not abrogate state sovereign immunity via § 1983)
- Mireles v. Waco, 502 U.S. 9 (absolute judicial immunity for judicial acts)
- Stump v. Sparkman, 435 U.S. 349 (scope of judicial immunity; bad-faith allegations do not defeat immunity)
- Cone v. Bell, 556 U.S. 449 (Brady due-process principles reiterated)
- Brady v. Maryland, 373 U.S. 83 (suppression of favorable evidence violates due process)
- City of Monterey v. Del Monte Dunes at Monterey, Ltd., 526 U.S. 687 (definition of § 1983 relief as remedy for deprivation under color of state law)
- West v. Atkins, 487 U.S. 42 (elements of a § 1983 claim)
- Huminski v. Corsones, 396 F.3d 53 (judicial immunity for security/order measures related to judicial functions)