Dothard v. United States of America

On October 4, 2021, Dennis Dothard, a prisoner proceeding pro se, filed a civil rights lawsuit against the United States of America in the U.S. District Court for the Northern District of Alabama under 42 U.S.C. § 1983. The case was assigned to Judge L Scott Coogler and Magistrate Judge Herman N Johnson. On September 27, 2023, the Magistrate Judge issued a report recommending dismissal of Dothard's monetary claims against Judge Borden and Kevin Ruben Sanchez with prejudice based on absolute immunity, and dismissal without prejudice of remaining federal claims for failure to state a claim. Dothard filed no objections. On October 31, 2023, Judge Coogler adopted the Magistrate Judge's report and recommendation in full, dismissing the monetary claims with prejudice and the remaining federal and state-law claims without prejudice.

The court adopted the Magistrate Judge's report and recommendation. Monetary claims against Judge Borden and Kevin Ruben Sanchez were dismissed with prejudice based on absolute immunity and frivolity. All remaining federal claims were dismissed without prejudice for failure to state a claim. Any state-law claims, including malpractice claims against defense attorneys, were dismissed without prejudice.

Whether Judge Borden and Kevin Ruben Sanchez were entitled to absolute immunity from monetary damages, and whether Dothard's remaining federal claims stated a claim upon which relief could be granted under 28 U.S.C. § 1915A.

This case illustrates the high bar prisoners face when bringing civil rights claims against judicial officers protected by absolute immunity. The dismissal under 28 U.S.C. § 1915A reflects federal courts' strict screening of prisoner lawsuits to weed out frivolous claims, balancing access to courts against judicial economy.