Background
William Sherratt filed a pro se action under federal civil rights statutes and Utah law against nineteen defendants, including judges and prosecutors involved in his 2000 rape convictions. He alleged that Judge Robert Braithwaite committed fraud by misstating his conviction counts in court orders and that other officials violated his rights by relying on those orders. The district court dismissed the case with prejudice, ruling that the defendants were immune or not proper parties, and the Tenth Circuit affirmed.
The court’s reasoning
The court affirmed the dismissal on multiple grounds. First, it held that state defendants are not persons under Sections one thousand nine hundred eighty-three and one thousand nine hundred eighty-five. Second, it ruled that absolute judicial immunity bars civil damages claims against judges, even for alleged fraud or bad faith, as established in Mireles v. Waco and Stump v. Sparkman. Third, the court found that prosecutors and state advocates in civil proceedings are entitled to absolute immunity. Finally, the court concluded that the complaint failed to meet pleading standards for certain individual defendants due to a lack of specific allegations.
What it means going forward
The decision reinforces the broad scope of absolute immunity for judges and prosecutors in civil rights litigation, making it difficult for plaintiffs to pursue damages against these officials for actions taken within their judicial or prosecutorial capacities.
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