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District Court May Not Enjoin Acts of State Judges, Ninth Circuit Declares
Repudiates Contrary 2004 Opinion
By a MetNews Staff Writer
Two putative class actions brought against the Los Angeles Superior Court and its then-presiding judge, Eric Taylor, alleging that bail was being impermissibly set at amounts in excess of what the plaintiffs could afford to pay, were properly dismissed with prejudice, the Ninth U.S. Circuit Court of Appeals declared yesterday, repudiating an earlier holding that federal courts may enjoin actions by state judges.
Judge Ryan D. Nelson wrote:
“We lack jurisdiction over these claims because actions against state courts and state court judges in their judicial capacity are barred by Eleventh Amendment immunity.”
That amendment says:
“The Judicial power of the United States shall not be construed to extend to any suit in law or equity, commenced or prosecuted against one of the United States by Citizens of another State, or by Citizens or Subjects of any Foreign State.”
Nelson said:
“[W]e conclude—as we have before—that the Superior Court of the State of California has sovereign immunity as an arm of the state.”
He added:
“Judge Taylor also has Eleventh Amendment immunity as a state judge.”
The apparent purpose of designating the opinion as one “for publication” was to repudiate the holding in the Ninth Circuit’s 2004 opinion in Wolfe v. Strankman that injunctive relief could be granted in federal court against state judges. Nelson pointed to the U.S. Supreme Court’s 2021 decision in Whole Woman’s Health v. Jackson which precludes any such relief.
“[S]tate court judges cannot be sued in federal court in their judicial capacity under the Eleventh Amendment,” Nelson wrote.
He said that “[t]o the extent Wolfe can be read to hold that” injunctions against state judges acting in their judicial capacity is permissible, “that conclusion is ‘clearly irreconcilable’ with Jackson and thus overruled.”
The case is Munoz v. Superior Court of Los Angeles County, 22-55941.
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