Hughes v. Duncan, No. 22-6004 (6th Cir. 2024)
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In a case heard before the United States Court of Appeals for the Sixth Circuit, plaintiff Jeffrey Hughes, an inmate in a Tennessee state prison, sued the Tennessee Board of Parole, alleging that the Board's refusal to move up his parole hearing date resulted in his overincarceration. Hughes believed that a recent change in state law entitled him to an earlier parole hearing. The Board refused his request, and he was paroled about three months after the date he believed he became eligible for release. The district court dismissed the case on the ground that the defendants, members of the Board, were absolutely immune from suit for their acts. Hughes then appealed.
The Court of Appeals affirmed the district court’s decision, holding that the members of the Tennessee Board of Parole were entitled to absolute immunity from damages suits challenging its decision on when to hold a parole hearing. The court found that the Board's decision to schedule (or not to reschedule) a parole hearing was a judicial act, akin to a judge scheduling a court hearing. As such, the defendants were acting in a quasi-judicial capacity and were entitled to absolute immunity. The court also rejected Hughes's arguments of judicial estoppel and res judicata, stating that the defendants could not have raised their immunity defense in the previous state suit and thus were not barred from raising it in the present federal suit.
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