Watkins v. City of Buffalo Impound
1:23-cv-01112
| W.D.N.Y. | Dec 1, 2024Background
- Tamara L. Watkins, proceeding pro se, filed a federal lawsuit against Buffalo City Court Judge Peter J. Savage III, claiming various constitutional violations stemming from proceedings regarding the seizure and later sale of her car by the City of Buffalo.
- Watkins’s car was seized by Buffalo police and later sold, along with her personal belongings; the City's denial of her claims for property loss led her to challenge the court proceedings.
- Watkins appeared before Judge Savage, who declined to review her jurisdictional challenge regarding the nature of the proceedings (criminal vs. traffic court), and rescheduled her case.
- Watkins sought money damages for actions taken by Judge Savage during court proceedings related to her seized vehicle.
- Judge Savage moved to dismiss the case, asserting, among other defenses, absolute judicial immunity.
- The district court, treating all of Watkins’s factual allegations as true, focused solely on the judicial immunity defense in its analysis.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Judge Savage is immune from suit | Savage had no jurisdiction; ignored challenge to court’s authority | All actions were judicial and within his jurisdiction as City Court Judge | Judge entitled to absolute judicial immunity |
| Whether monetary damages can be sought | Requested damages for rights violations | Judicial immunity bars damages for judicial actions | Damages barred by judicial immunity |
| Applicability of judicial immunity to City Court judge | Judicial immunity applies only to federal judges | Immunity applies to state and city judges as well | Immunity applies to City Court judge |
| Opportunity to amend complaint | No explicit argument | Leave to amend should be denied as futile | Amendment futile; no leave granted |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (sets out federal pleading standard for Rule 12(b)(6), plausibility requirement)
- Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007) (establishes plausibility standard for motions to dismiss)
- Mireles v. Waco, 502 U.S. 9 (1991) (explains scope and policy rationale for absolute judicial immunity)
- Stump v. Sparkman, 435 U.S. 349 (1978) (defines limits and breadth of judicial immunity for judicial acts)
- Bradley v. Fisher, 80 U.S. 335 (1871) (historic SCOTUS anchor decision on judicial immunity boundaries)
- Bliven v. Hunt, 579 F.3d 204 (2d Cir. 2009) (Second Circuit authority further detailing judicial immunity doctrine)