Turner v. Go Auto Insurance Co, 5:22-cv-00582-EEF-MLH

Jeffrey V. Turner, proceeding pro se and IFP, sued in federal court complaining about handling of his 2019 Caddo Parish auto‑accident suit against Go Auto Insurance and asking for damages and a jury trial.
Turner named state judges Ramon Lafitte and Roy Brun and deputy clerk Colvin Roberson, alleging judicial and clerk misconduct (e.g., ejecting him, misrepresenting law, refusing filings). He alleged events occurring in 2019 but did not file federally until 2022.
The magistrate judge reviewed the IFP complaint under 28 U.S.C. § 1915(e)(2)(B) and Fed. R. Civ. P. 12(b)(6) standards and issued a Report & Recommendation to dismiss.
The court held that damages claims against the two judges are barred by absolute judicial immunity for acts within their judicial functions.
Claims against the deputy clerk are barred by quasi‑judicial/absolute immunity for tasks integral to the judicial process and are also time‑barred under Louisiana’s one‑year prescription as applied to § 1983 accrual rules.
The magistrate also found the federal court cannot act as an appellate forum to reverse state‑court judgments (i.e., federal relief is not available to relitigate state proceedings) and recommended dismissal for failure to state a claim. Parties have 14 days to file objections.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Damages claims against state judges under § 1983	Turner contends judges acted improperly and violated his civil rights in state proceedings	Judges’ actions were judicial acts entitled to absolute judicial immunity	Claims dismissed: absolute judicial immunity bars damages against judges
2. Damages claims against deputy clerk	Turner alleges clerk refused filings and told him case closed, denying access	Clerk is immune for actions integral to judicial process; routine duties may have qualified immunity	Claims dismissed: quasi‑judicial immunity applies; thus no damages liability
3. Timeliness of claims against clerk	Turner asserts ongoing injury from clerk’s 2019 actions	Defendants argue claims accrued in 2019 and are prescribed under Louisiana’s one‑year rule for torts (borrowed for § 1983)	Claims dismissed as time‑barred: suit filed in 2022, beyond one‑year prescription
4. Federal court authority to review state court judgment	Turner seeks federal relief to remedy state court rulings	Defendants contend federal courts lack appellate jurisdiction to overturn state court final orders	Dismissal recommended: federal court cannot relitigate or reverse state court judgments

Mireles v. Waco, 502 U.S. 9 (1991) (judicial immunity protects judges for judicial acts)
Pierson v. Ray, 386 U.S. 547 (1967) (judicial immunity applies even when judge acted maliciously)
Clay v. Allen, 242 F.3d 679 (5th Cir. 2001) (clerk immunity rules)
Tarter v. Hury, 646 F.2d 1010 (5th Cir. 1981) (clerk qualified/absolute immunity analysis)
Mylett v. Mullican, 992 F.2d 1347 (5th Cir. 1993) (absolute quasi‑judicial immunity for clerks performing integral judicial tasks)
Elzy v. Roberson, 868 F.2d 793 (5th Cir. 1989) (Louisiana prescription borrowed for § 1983 claims)
Burrell v. Newsome, 883 F.2d 416 (5th Cir. 1989) (accrual rule for § 1983 claims: when plaintiff knows or should know of facts)
Eitel v. Holland, 787 F.2d 995 (5th Cir. 1986) (federal courts lack jurisdiction to modify or nullify final state court orders)
Rogers v. Boatright, 709 F.3d 403 (5th Cir. 2013) (frivolousness standard under § 1915(e)(2))