Walton v. Bryant
4:25-cv-00585
E.D. Mo.Jun 12, 2025Background
- Plaintiff DeAndre Walton, an inmate at the Eastern Reception Diagnostic and Correctional Center in Missouri, brought a pro se action under 42 U.S.C. § 1983 against Judge Paula Bryant, who presided over his criminal case.
- Walton was previously charged and convicted in St. Louis Circuit Court of first-degree murder, armed criminal action, and unlawful possession of a firearm, receiving a life sentence.
- Walton alleges multiple constitutional violations by Judge Bryant during the criminal proceedings, including denial of various procedural and substantive rights.
- Walton sought leave to proceed in forma pauperis, but did not submit a prison account statement; the Court assessed a $1 partial filing fee.
- The action seeks $5 million in damages and is subject to initial review under 28 U.S.C. § 1915(e)(2), requiring dismissal if the complaint is frivolous, malicious, or fails to state a claim.
- The Court dismissed the action without prejudice, citing judicial immunity for actions taken within Judge Bryant’s judicial capacity and jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can a judge be sued for constitutional violations under § 1983 | Bryant violated Walton’s rights during proceedings | Actions were taken in judicial capacity and within jurisdiction | Judicial immunity applies; case dismissed |
| Sufficiency of factual allegations under § 1915 review | Walton alleged constitutional deprivations | Claims are conclusory, not sufficient to bypass immunity | Allegations insufficient to overcome immunity |
| Applicability of judicial immunity to requested relief | Walton seeks monetary damages for judicial actions | Judges are absolutely immune from such lawsuits | Bryant immune from suit, no relief possible |
| Leave to amend complaint | Walton could amend the complaint | Amendment would not alter legal bar to claims | No leave to amend granted |
Key Cases Cited
- Mireles v. Waco, 502 U.S. 9 (absolute judicial immunity bars suit for actions taken in judicial capacity and with jurisdiction)
- Pierson v. Ray, 386 U.S. 547 (judicial immunity applies even when judge is accused of malicious or corrupt conduct)
- Ashcroft v. Iqbal, 556 U.S. 662 (plausibility standard for stating a claim under federal pleading rules)
- Haines v. Kerner, 404 U.S. 519 (liberal construction of pro se pleadings)