Reported / Citable
Background
Charleston Singletary sued Theresa May and four current or former federal judicial officers: Senior Judges Kenneth Hoyt and Lee Rosenthal, Judge Charles Eskridge, and former Magistrate Judge Sam Sheldon. His complaint invoked federal civil-rights and criminal statutes and arose from the handling of three habeas proceedings he filed beginning in 2020.
Singletary alleged that the judicial defendants discriminated against him by characterizing and treating him as a prisoner, issuing or declining to issue certain orders, adding parties, correcting case captions, supervising proceedings, and declining to respond to attempted ex parte communications. The judicial defendants moved to dismiss, and Singletary did not respond. The court nevertheless considered the motion on its merits.
The Court’s Holding
The court granted the judicial defendants’ motion to dismiss because absolute judicial immunity protected the challenged conduct. Applying the governing test for whether conduct is judicial in nature, the court concluded that Singletary’s allegations concerned ordinary judicial functions performed while managing cases pending before the defendants, including issuing orders, supervising proceedings, identifying parties, and maintaining case captions.
The complaint did not place the conduct within either exception to judicial immunity: nonjudicial action or judicial action taken in the complete absence of jurisdiction. The court therefore dismissed the claims against Hoyt, Rosenthal, Eskridge, and Sheldon. It also granted Singletary leave to proceed in forma pauperis and gave him until December 31, 2026, to serve the remaining defendant, Theresa May.
Key Takeaways
- Federal judges are absolutely immune from liability for judicial acts unless they act outside their judicial capacity or in the complete absence of jurisdiction.
- Issuing or declining to issue orders, managing parties and captions, supervising proceedings, and handling attempted ex parte communications are judicial functions when performed in connection with pending cases.
- The dismissal resolved the claims against the four judicial defendants, but the case remained pending against Theresa May, whom Singletary received additional time to serve.
Why It Matters
The order illustrates the breadth of absolute judicial immunity in civil-rights litigation. Allegations that judicial rulings or case-management decisions were discriminatory do not, without more, transform those acts into nonjudicial conduct or establish that the judges acted entirely without jurisdiction.
It also underscores that a party’s failure to oppose a motion does not necessarily end the analysis: although local rules allowed the court to treat the silence as nonopposition, the court addressed the immunity defense on its merits.