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Elhadj Alpha Mahmoud Souare v. Elisa Hill, Chief Magistrate Judge, Summit County Domestic Relations Court, Ohio, et al.
IFP petition · United States Court of Appeals for the Sixth Circuit, No. 25-3668 · judgment April 6, 2026
Question presented
I. Whether the Younger abstention doctrine applies when a state court's own procedural violations — such as the same-day adoption of a magistrate's decision in violation of a mandatory objection window — eliminate the adequate opportunity to raise federal constitutional claims that Younger presupposes, thereby creating a complete foreclosure of all judicial remedies for admitted due process violations. II. Whether the functional immunity test of Cleavinger v. Saxner, 474 U.S. 193 (1985), and Forrester v. White, 484 U.S. 219 (1988), extends absolute quasi-judicial immunity to courtappointed officers for purely ministerial and administrative acts — including the maintenance of court records, processing of judicial notices, and conduct of court-ordered investigations — that are independent of the adjudicatory process, where the Third Circuit limits such immunity strictly to core judicial functions and the Sixth and Eighth Circuits extend immunity to all courtappointed duties. III. Whether, if absolute quasi-judicial immunity does not apply to ministerial and administrative acts by court-appointed officers, such officers are entitled to qualified immunity under 42 U.S.C. § 1983, where the district court never reached the qualified immunity analysis because it granted absolute immunity categorically.
Counsel of record
For petitioner
Elhadj Alpha Mahmoud Souare
For respondent
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Case
Subject area
Civil Rights (estimated from the questions presented, in the Supreme Court Database’s categories)
Conference history
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Proceedings
- Apr 10 2026Petition for a writ of certiorari and motion for leave to proceed in forma pauperis filed. (Response due October 19, 2026)