Stiggle v. Tamburini

Citations: 467 F. Supp. 2d 183; 2006 WL 3827455Docket: CA06-138S

Court: District Court, D. Rhode Island; December 27, 2006; Federal District Court

SummaryOriginalCytator Case TreatmentAnalysis

EnglishEspañolSimplified EnglishEspañol Fácil

Eric J. Stiggle, Sr. filed an Amended Complaint under 42 U.S.C. § 1983, alleging violations of his constitutional rights against several police officers from Johnston, Rhode Island, and Stephen Peltier, a Justice of the Peace. The complaint stemmed from an incident on November 18, 2004, when Stiggle and his wife, wanted by Connecticut authorities, were arrested in a motel room without a warrant. Stiggle claims that after being taken to the police station, he was disrespectful to officers, and that Officer Deangelis punched him during processing. Peltier arraigned Stiggle in a cell and requested a $200 fee, which Stiggle refused to pay. Despite his refusal, an officer allegedly took $200 from Stiggle's pocket to pay the fee. Following his arraignment, Stiggle became ill during transport to a correctional facility and received medical attention.

Peltier moved to dismiss the claims against him, arguing judicial immunity, which Stiggle opposed. The matter was referred to Senior United States Magistrate Judge Jacob Hagopian, who recommended granting Peltier's motion to dismiss. The court accepted this recommendation, as no objections were filed, leading to the dismissal of Stiggle's claims against Peltier based on judicial immunity, as per the standards set by Rule 12(b)(6) of the Federal Rules of Civil Procedure. The court must accept the complaint's well-pleaded facts as true and view them in the plaintiff's favor when considering such motions.

A Rule 12(b)(6) motion is granted only when it is evident that the plaintiff cannot prove any facts that would support a claim for relief. Courts do not accept unsubstantiated assertions or subjective characterizations when reviewing such motions. The focus is on whether the complaint includes sufficient factual allegations to support claims of federal rights deprivation under 42 U.S.C. § 1983. This section allows individuals to sue for the denial of federally protected rights by state actors. The initial assessment in a § 1983 case involves determining if the defendant acted under state law and whether this conduct deprived the plaintiff of constitutional or statutory rights. 

Defendant Peltier argues that judicial immunity protects him from this lawsuit. The principle of judicial immunity, established by the Supreme Court, asserts that judges are not liable for their judicial actions, even if performed maliciously or outside their jurisdiction, as long as they possess some jurisdiction over the subject matter. Judges retain this immunity unless they act entirely outside their jurisdiction. For example, a judge lacking authority over a specific case cannot claim immunity if they proceed in a matter outside their jurisdiction.

A judge in a criminal court retains immunity even if a defendant is convicted of a non-existent crime, as long as the judge has jurisdiction over the subject matter. This immunity applies to justices of the peace. In this case, the plaintiff claims that defendant Peltier improperly collected a $200 fee after the plaintiff's arraignment. However, Peltier had jurisdiction to conduct the arraignment and set bail under Rhode Island law, which permits justices of the peace to collect fees up to $200. Thus, Peltier acted within his jurisdiction and is entitled to absolute immunity from liability for his actions, regardless of their correctness. Therefore, it is recommended that Peltier's motion to dismiss be granted. Any objections to this recommendation must be specific and filed within ten days; failure to do so waives the right to district court review and appeal.