Falkner v. Blanton

Background

A person sued a Florida probate judge under the federal civil-rights law (42 U.S.C. § 1983) saying the judge refused to award property that was clearly due under a will. The plaintiff asked for money, a court order, and a formal declaration of rights. The federal trial court dismissed the case on its own, saying the judge was immune from suit, and the Court of Appeals affirmed without an opinion. The Supreme Court did not take the case—the petition for review was denied.

Reasoning

The key question raised by the dissenting Justice was whether judges can be shielded from all kinds of relief when someone sues under the civil-rights law, especially when the suit seeks a court order or declaration rather than only money damages. The dissent argued that an earlier decision had added a reading to the statute that blocks money claims against judges, but that the same reasoning should not automatically block requests for injunctions or declarations. The dissent cited other appellate decisions that had treated requests for court orders differently from money claims and said the statute’s plain words cover judges.

Real world impact

Because the high court declined review, the dismissal based on judicial immunity stands in this case. That outcome leaves the plaintiff without the requested money or court orders to get the property. The dissent said allowing equitable relief would not threaten judicial independence, but that view did not carry the day here.

Dissents or concurrances

Justice Douglas dissented: he would have granted review and reversed, urging that judges not be immune from suits seeking equitable relief under the civil-rights statute.