Background
Sheila Halousek filed a pro se lawsuit in the United States District Court for the Northern District of California alleging various constitutional and statutory violations against state court judges and a court commissioner. The district court dismissed the complaint, and Halousek appealed.
The court’s reasoning
The panel reviewed the dismissal de novo. The court affirmed because the claims against state court officials were barred by judicial immunity. The court also affirmed the dismissal of remaining claims because the complaint was filed outside the two-year statute of limitations for personal injury claims under California law. Additionally, the court held that the criminal statute under eighteen U.S.C. Section two four two does not give rise to civil liability.
What it means going forward
The decision reinforces that state court officials acting in a judicial capacity are immune from civil suits under Section one nine eight three and clarifies that the criminal statute under eighteen U.S.C. Section two four two cannot be used to assert civil liability.
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