MUNOZ V. SUPERIOR COURT OF LOS ANGELES COUNTY, No. 22-55941 (9th Cir. 2024)
Annotate this CaseIn a case involving a putative class of plaintiffs who alleged that the Superior Court of Los Angeles County and Judge Eric C. Taylor set cash bail that they could not afford and unlawfully detained them pretrial, the United States Court of Appeals for the Ninth Circuit affirmed the district court's dismissal of the action. The court held that actions against state courts and state court judges in their judicial capacity are barred by Eleventh Amendment immunity. The Superior Court of California was found to have sovereign immunity as an arm of the state. The court concluded that the exception in the Ex parte Young case did not apply because the Superior Court cannot be sued in an individual capacity. The court also held that Judge Taylor had Eleventh Amendment immunity because state court judges cannot be sued in federal court in their judicial capacity under the Eleventh Amendment. The court overruled any interpretation of a previous case (Wolfe v. Strankman) that suggested the Ex parte Young exception allowed injunctions against judges acting in their judicial capacity, finding such interpretation to be clearly irreconcilable with a more recent Supreme Court decision (Whole Woman’s Health v. Jackson). The court concluded that it lacked jurisdiction to resolve claims brought against state courts or state court judges acting in a judicial capacity due to Eleventh Amendment immunity.
Court Description: Eleventh Amendment Immunity The panel affirmed the district court’s dismissal of two putative class actions brought pursuant to 42 U.S.C. § 1983 against the Superior Court of Los Angeles County and Judge Eric C. Taylor, alleging that defendants set cash bail that plaintiffs could not afford and therefore unlawfully detained them pretrial.
The panel held that actions against state courts and state court judges in their judicial capacity are barred by Eleventh Amendment immunity.
The Superior Court of the State of California had sovereign immunity as an arm of the state. The exception in Ex parte Young, 209 U.S. 123 (1908), did not apply because the Superior Court cannot be sued in an individual capacity.
Judge Taylor had Eleventh Amendment immunity because state court judges cannot be sued in federal court in their judicial capacity under the Eleventh Amendment. To the extent that Wolfe v. Strankman, 392 F.3d 358 (9th Cir. 2004), can be read to hold that the Ex parte Young exception allows injunctions against judges acting in their judicial capacity, that conclusion is clearly irreconcilable with Whole Woman’s Health v. Jackson, 595 U.S. 30 (2021), and thus overruled.
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