Balubhai Patel, et al. v. Julie A. Su, et al.

Prior to the 1996 amendment to 42 U.S.C. § 1983, this Court held that judicial immunity for state defendants does not extend to actions for declaratory or injunctive relief. See Pulliam v. Allen, 466 U.S. 522, 541-542 (1984). In 1996, Congress amended § 1983 to prohibit the grant of injunctive relief against any judicial officer acting in his or her official capacity “unless a declaratory decree was violated or declaratory relief was unavailable.” 42 U.S.C. § 1983; Federal Courts Improvement Act of 1996, § 309(c), Pub. L. No. 104-317, 110 Stat. 3847, 3853 (1996) (amending 42 U.S.C. § 1983). Federal circuit and state appellate courts are divided on whether the statutorily-enacted immunity from injunctive relief applies to non-judges performing judicial functions. Some courts hold that the immunity from injunctive relief in § 1983 actions does extend to quasi-judicial situations, see Montero v. Travis, 171 F.3d 757, 761 (2nd Cir. 1999); Roth v. King, 449 F.3d 1272, 1286-1287 (D.C. Cir. 2006), while other courts hold that immunity does not apply to quasi-judicial officers. See Simmons v. Fabian, 743 N.W.2d 281, 285- 294 (2007). The California Court of Appeal held that even if quasi-judicial immunity does not apply under § 1983 as to claims for declaratory and injunctive relief against the California Labor Commissioner, they were barred under state law. The questions presented are:

1. Whether the California Court of Appeal erred in holding that petitioners’ claims under 42 U.S.C. § 1983 for declaratory and injunctive relief were barred as a matter of state law?

2. To resolve a split between the federal circuit and state appellate courts, does 42 U.S.C. § 1983 extend quasi-judicial immunity to claims for injunctive relief?