Mary Louise Serafine v. Karin Crump, et al.

Section 1983 of Title 42 applies to state actors who are judges. Although damages are barred by judicial immunity, prospective relief against state judges is available for acts taken in their “judicial capacity.” 42 U.S.C. § 1983. Awarding such relief requires a future state court proceeding in which the relief would take effect. Petitioner sustained rife, intentional, and bad faith denials of due process in a civil case in Texas state court. To stop continuation of the harm, Petitioner sought prospective relief in federal court, intended to take effect in future proceedings of the same state case. The Fifth Circuit dismissed. It reasoned that Petitioner lacked Article III standing under its expansive interpretation of City of Los Angeles v. Lyons, 461 U.S. 95 (1983). In Lyons, plaintiff suffered an unprovoked police choke hold during a traffic stop. Later Mr. Lyons unsuccessfully sought an injunction to ban the choke hold practice. The Court held that he failed to show he would again be choked in a future traffic stop. Extending Lyons to Petitioner’s case, the Fifth Circuit held that Petitioner lacked standing regardless of whether her state case was still in progress. The question presented is: Whether City of Los Angeles v. Lyons may be expanded to bar Article III standing under Section 1983 in a suit for prospective relief against state judges, when the case in question is still in progress.