9th Cir.

Cyrus Sanai v. Alex Kozinski, et al

June 18, 2026 ·4:19-cv-08162-YGR ·Unpublished · By Aisha Johnson

The Ninth Circuit affirmed a district court dismissal of a civil rights lawsuit against federal judges and court officials. The panel held that sovereign immunity and judicial immunity barred the plaintiff's claims.

Background

Plaintiff Cyrus Sanai appealed a district court order granting defendants’ motion to dismiss and denying his motion to amend, along with several post-judgment motions including requests for recusal. The case involved claims against federal judges, court staff, and the Judicial Council of the Ninth Circuit.

The court’s reasoning

The court affirmed the dismissal based on sovereign immunity for the Judicial Council, noting the Administrative Procedure Act excludes courts of the United States from its waiver of immunity. The court held that judges and staff retain absolute judicial immunity for judicial acts, including sanctioning attorneys, and that recusal was not necessary as there was no evidence of bias.

What it means going forward

The ruling reinforces that federal judges and the Ninth Circuit Judicial Council are shielded from civil liability for judicial and administrative acts, and limits the ability to challenge judicial conduct through civil suits or recusal motions absent compelling evidence of bias.