Dennis v. Sparks
Annotate this Case
449 U.S. 24 (1980)
U.S. Supreme Court
Dennis v. Sparks, 449 U.S. 24 (1980)
Dennis v. Sparks
Argued October 8, 1980
Decided November 17, 1980
449 U.S. 24
After a Texas state court's injunction against respondents' production of minerals from certain oil leases was dissolved by an appellate court as having been illegally issued, respondents filed suit in Federal District Court alleging a cause of action for damages under 42 U.S.C. § 1983 against the judge who issued the injunction, the corporation that had obtained the injunction, its owner, and the sureties on the injunction bond (one of whom is the petitioner). Respondents claimed that the injunction had been corruptly issued as the result of a conspiracy between the judge and the other defendants, thus causing a deprivation of property without due process of law. The District Court dismissed the action, holding that the judge was immune from liability in a § 1983 suit because the injunction was a judicial act within the jurisdiction of the state court, and that, with the dismissal of the judge, the remaining defendants could not be said to have conspired "under color" of state law within the meaning of § 1983. The Court of Appeals agreed that the judge was immune from suit, but ultimately reversed as to the dismissal of the claims against the other defendants.
Held: The action against the private parties accused of conspiring with the judge is not subject to dismissal. Private persons, jointly engaged with state officials in a challenged action, are acting "under color" of law for purposes of § 1983 actions. And the judge's immunity from damages liability for an official act that was allegedly the product of a corrupt conspiracy involving bribery of the judge does not change the character of his action or that of his coconspirators. Historically at common law, judicial immunity does not insulate from damages liability those private persons who corruptly conspire with a judge. Nor has the doctrine of judicial immunity been considered historically as excusing a judge from responding as a witness when his coconspirators are sued, even though a charge of conspiracy and judicial corruption will be aired and decided. Gravel v. United States, 408 U. S. 606, distinguished. The potential harm to the public from denying immunity to coconspirators if the factfinder mistakenly upholds a charge of a corrupt conspiracy is outweighed by the benefits of providing a remedy
against those private persons who participate in subverting the judicial process and, in so doing, inflict injury on other persons. Pp. 449 U. S. 27-32.
604 F.2d 976, affirmed.
WHITE, J., delivered the opinion for a unanimous Court.
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