Watson v. Thomas (INMATE1)
2:11-cv-00938
M.D. Ala.Jan 19, 2012Background
- Watson, a prisoner, sues multiple defendants in the Middle District of Alabama seeking relief under 42 U.S.C. §1983.
- Magistrate Judge recommended transferring the case to the Northern District of Alabama.
- Watson objected to transfer, arguing most defendants reside in this district and most actions occurred here.
- Complaint shows most actions occurred at Bibb Correctional Facility; testing and state court rulings occurred in this district.
- The court independently reviewed the objections and adopted the transfer recommendation under 28 U.S.C. §1404.
- The court noted state judges enjoy absolute immunity from damages and considered the Rooker-Feldman doctrine and potential state-actor status of the independent laboratory in deciding the transfer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the case should be transferred to the Northern District of Alabama | Watson argues venue should stay in this district | Defendants advocate transfer under §1404 based on convenience and proper forum | Transfer granted under §1404 |
| Whether state judges are immune from §1983 damages | States judges may be liable for actionable conduct | Judicial immunity shields damages | Judicial immunity applies; damages claims against state judges are improper |
| Rooker-Feldman doctrine applicability to state-court judgments | Watson disputes preclusive effect of state-court judgments | Doctrine bars such challenges in federal court | Rooker-Feldman applies to bar this type of challenge |
| Whether independent lab employees are state actors for §1983 | Lab employees may be state actors due to state contracting | Lab independence and lack of constitutional duty negate state-actor status | Disposition left to Northern District; no definitive state-actor status found here |
Key Cases Cited
- Bolin v. Story, 225 F.3d 1234 (11th Cir. 2000) (state judges immune from damages for acts while acting; absolute immunity)
- Lance v. Dennis, 546 U.S. 459 (Sup. Ct. 2006) (Rooker-Feldman prevents lower courts from reviewing state-court judgments)
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (Sup. Ct. 2005) (Rooker-Feldman context and jurisdictional concerns)
- Datz v. Kilgore, 51 F.3d 252 (11th Cir. 1995) (§1983 action inappropriate to compel or appeal state court decisions)
- Rolleston v. Eldridge, 848 F.2d 163 (11th Cir. 1988) (state-court judgment challenges barred as improper appeal)
- West v. Atkins, 487 U.S. 42 (Sup. Ct. 1988) (private contractor as state actor when vested with state authority)