Silverman v. Reinholtsen, 3:17-cv-03194

Plaintiff, an inmate at Humboldt County Correctional Facility, sued state judge Dale Reinholtsen under 42 U.S.C. § 1983 after the judge denied his renewed motion to suppress evidence.
Plaintiff alleges the judge ignored controlling law, invented facts, and thereby violated his Fourteenth Amendment equal protection and due process rights and Fourth Amendment protections.
The matter was screened under 28 U.S.C. § 1915A; plaintiff proceeds pro se.
The court examined judicial immunity, Rooker–Feldman jurisdictional limits on federal review of state-court judgments, and Younger abstention regarding ongoing state proceedings.
The court concluded the judge’s actions were judicial acts entitled to absolute immunity and that federal district courts lack subject-matter jurisdiction to review state-court rulings under Rooker–Feldman; Younger abstention also barred interference with any ongoing state proceedings.
The complaint was dismissed with prejudice and leave to amend to add the County of Eureka was denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Judge Reinholtsen is liable under § 1983 for denying the motion to suppress	Reinholtsen acted improperly, ignored law, and fabricated facts, violating Fourteenth and Fourth Amendment rights	Judicial acts are immune; the judge acted in his judicial capacity	Dismissed: judge has absolute judicial immunity for acts in judicial capacity
Whether the federal court may review and reverse the state-court ruling	Silverman seeks federal relief for an allegedly erroneous state-court decision	Federal district court lacks jurisdiction to review state-court judgments (Rooker–Feldman)	Dismissed: Rooker–Feldman bars de facto appeal to federal district court
Whether leave to amend to add County of Eureka should be permitted	Requests leave to add county as defendant	Amendment cannot cure jurisdictional defect or evade Rooker–Feldman/Younger; claims still barred	Denied: amendment futile because jurisdictional/abstention bars remain
Whether federal court should abstain due to ongoing state proceedings	Plaintiff seeks relief that could affect state proceedings	Younger abstention precludes federal interference absent extraordinary circumstances	Abstention appropriate; federal court should not intervene in ongoing state criminal matters

Pierson v. Ray, 386 U.S. 547 (judicial immunity for judges in § 1983 suits)
Stump v. Sparkman, 435 U.S. 349 (definition and scope of judicial acts for immunity)
Mireles v. Waco, 502 U.S. 9 (judicial immunity not overcome by allegations of bad faith or malice)
West v. Atkins, 487 U.S. 42 (elements for § 1983 liability)
Rooker v. Fidelity Trust Co., 263 U.S. 413 (federal courts cannot review state-court judgments)
District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (Rooker–Feldman doctrine scope)
Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (limits Rooker–Feldman to cases that are de facto appeals of state judgments)
Younger v. Harris, 401 U.S. 37 (abstention where federal relief would interfere with ongoing state proceedings)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (plausibility pleading standard)
Erickson v. Pardus, 551 U.S. 89 (liberal construction of pro se complaints)