Justice Network Inc. v. Craighead County, No. 17-3770 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the district court's dismissal of TJN's 42 U.S.C. 1983 action against defendants, in an action arising from the Craighead County District Judges Boling and Fowler's implementation of an Amnesty Program forgiving all fees that probationers owed to TJN for probation services. The court held that Judges Boling and Fowler were entitled to absolute judicial immunity against all of TJN's claims, because Arkansas judges have authority to suspend the imposition of fines in criminal cases and may modify terms and conditions of supervision. Furthermore, TJN's request for declaratory relief was retrospective and thus it was not entitled to such relief under section 1983. The court also rejected the municipal liability claims and held that the judges are state government officials whose actions are not attributable to the county or city defendants.
Court Description: Smith, Author, with Kelly and Kobes, Circuit Judges] Civil case - Civil rights. In action alleging two Craighead County, Arkansas District Judges violated plaintiff's civil rights when they declared an amnesty program for fees probation clients owed plaintiff for probation supervision services, the judges were entitled to absolute judicial immunity on all of plaintiff's claims as Arkansas judges have authority to suspend the imposition of fines in criminal cases and may modify terms and conditions of supervision; additionally, the judges are state government employees and their decisions could not create municipal liability under Section 1983; plaintiff's request for declaratory relief is retrospective and seeks, in essence, to invalidate the actions of the judges; as a result, plaintiff is not entitled to declaratory relief; the district court did not err in dismissing the claims against Craighead County and the City defendants as the judges are state employees, not employees of the County or the cities, and the judges' actions cannot be imputed to them.
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