Case Explained: LOREN RANCOURT V. JOEL BOLGER, ET AL

Court: United States Court of Appeals for the Ninth Circuit

Filed: 2026-07-08

Docket: 3:21-cv-00189-JMK

The Ninth Circuit affirmed the district court’s dismissal of Loren Rancourt’s civil rights action against various state and municipal officials under 42 U.S.C. § 1983. The court held that the district court correctly applied absolute judicial immunity to state court judges and staff for their judicial acts and processing of filings, citing *Stump v. Sparkman* and *Demoran v. Witt*. Additionally, the court affirmed the dismissal of claims against a municipal prosecutor based on absolute prosecutorial immunity for acts performed in an advocacy capacity under *Ashelman v. Pope*. The court further ruled that claims seeking injunctive or declaratory relief regarding state court judgments were barred by the Rooker-Feldman doctrine, which prohibits federal courts from exercising jurisdiction over suits that function as de facto appeals of state court decisions. Finally, the court upheld the dismissal of claims against the Municipality of Anchorage because the plaintiff failed to allege specific facts demonstrating a municipal policy or custom that violated his constitutional rights, failing to meet the standards set forth in *Connick v. Thompson* and *Ashcroft v. Iqbal*, and failing to show that any municipal code provision shocked the conscience under substantive due process principles. As a result of this affirmation, the dismissal of Rancourt’s claims stands, and no relief is granted.

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