An inmate, James Ray Bartlett, convicted of passing worthless checks, sued six court officers alleging conspiracy, constitutional rights violations, and other misconduct, seeking sanctions against them and $33 million in damages. The Circuit Court dismissed his complaint for failure to state a claim, which Bartlett appealed. His criminal history includes multiple convictions, and he initially received consecutive sentences for his offenses. After a hearing, the trial court affirmed the dismissal of his claims, leading to the current appeal. The appellate court, with all judges concurring, affirmed the lower court's judgment, issuing a memorandum opinion that is not to be published or cited in unrelated cases.
Mr. Bartlett alleges a conspiracy involving multiple parties, claiming that clerical errors related to his appeals process are indicative of wrongdoing. He was convicted of several misdemeanors, including passing worthless checks, and subsequently filed a Notice of Appeal on June 18, 2001. The Circuit Court Clerk, Gail Corder, amended this notice by removing references to the worthless check charges, based on advice from Assistant District Attorney Charles Grubbs, who stated that these charges could not be appealed due to Mr. Bartlett's guilty plea. Mr. Bartlett then accused Corder of attempting to manipulate the appeal process.
On September 4, 2001, the District Attorney moved to dismiss all pending charges to avoid a jury trial, rendering the original Notice of Appeal moot. Following this, Mr. Bartlett, advised by his court-appointed counsel, filed another Notice of Appeal referencing only the worthless check charges. The District Attorney subsequently attempted to dismiss this new appeal on grounds of late filing, but withdrew the motion when it was clarified that a timely notice had been filed.
During the sentencing hearing, Mr. Bartlett testified about the disputed checks, and the court imposed concurrent sentences for the charges. He argues that the dismissal of all charges on September 4 included the worthless checks and claims coercion by his attorney to appeal the voided charges, asserting a conspiracy among the court officials to reinstate his convictions. The defense counters that the September 4 dismissal only voided the charges contested in General Sessions, maintaining that the worthless check charges remained final due to his guilty plea and that Mr. Self acted to protect Mr. Bartlett's right to appeal. The court finds the defendants' arguments persuasive, noting Mr. Bartlett's admission of a "mistake" made by the defendants in handling the appeal process, while he still asserts that the use of white-out represents a judicial travesty.
Judicial mistakes or ambiguities do not imply conspiracy without specific evidence. Under Tenn. R. Civ. P. 12.02(6), a trial court must accept all well-pleaded material factual allegations as true, interpreting the complaint favorably for the plaintiff. However, a mere allegation of conspiracy lacks the presumption of truth and must be supported by factual claims that, if proven, would substantiate a conspiracy. An actionable civil conspiracy requires a combination of individuals with shared intent to achieve an unlawful purpose or a lawful one through unlawful means, resulting in damage to the plaintiff. The plaintiff's allegations lacked the necessary intent and concerted action to support a conspiracy claim, and he failed to demonstrate any damage from the defendants' actions, which actually reduced his total time served. Thus, the trial court's dismissal of his complaint was affirmed.
Even if the conspiracy claims were sufficiently specific, immunity and other defenses would still bar relief. Official misconduct and oppression are criminal offenses subject to penalties but do not create a private right of action. Malicious prosecution requires that the prior action was terminated in the plaintiff's favor; since the plaintiff pled guilty, this requirement was unmet, leading to proper dismissal. Judicial immunity protects judges performing their roles within jurisdiction, shielding them from lawsuits aimed at discouraging principled decision-making. Prosecutors also enjoy immunity for actions taken in their prosecutorial capacity, reflecting similar protections afforded to judges and grand jurors acting within their duties.
Concerns are raised about potential harassment from unfounded litigation affecting a prosecutor's duties and the independence of his judgment. The doctrine of judicial immunity has been extended in Tennessee and other states to include individuals such as court clerks, to protect them from litigation that might arise from disappointed litigants. Courts acknowledge that these litigants may target clerks and similar personnel when unable to sue judges directly, thus granting absolute quasi-judicial immunity to court personnel for actions integral to the judicial process.
Mr. Bartlett’s grievance against Court Clerk Gail Corder, related to her altering his Notice of Appeal by whiting out case numbers, does not warrant a determination of judicial immunity since any conspiracy claim against her was dismissed. Claims of official misconduct or oppression are also invalid as there is no private right of action for such allegations.
Mr. Bartlett’s attorney, Mr. Self, faces similar challenges; he does not possess the same immunities as judicial officials. Bartlett's complaint against Self revolves around advice regarding a subsequent Notice of Appeal and inaction concerning the altered case numbers. However, this claim is seen as weak since the district attorney's dismissal of charges did not affect existing convictions. Instead, Mr. Self’s actions safeguarded Bartlett's right to appeal, ultimately benefiting him. The court concludes that Bartlett has not established a valid claim against his attorney. The trial court's judgment is affirmed, and the case is remanded to the Circuit Court of Lincoln County for further proceedings, with costs taxed to Bartlett.
