CLEARY GIACOBBE ALFIERI JACOBS OBTAINS DISMISSAL OF A CONSTITUTIONAL CLAIM IN FEDERAL DISTRICT COURT AGAINST A MUNICIPALITY AND ITS MUNICIPAL COURT OFFICIAL BASED ON JUDICIAL IMMUNITY

On July 22, 2025, the Honorable Zahid N. Quraishi, U.S.D.J., in the United States District Court for the District of New Jersey, issued an opinion in Carolyn Peterson-Daily v. City of Asbury Park, et al., dismissing the Plaintiff’s claim against the City and its Municipal Court Officials for alleged violations of the Plaintiff’s Sixth and Fourteenth Amendment Constitutional rights and 42 U.S.C. § 1983. The Court dismissed the Plaintiff’s Complaint based on the well-established immunities afforded to judges, prosecutors, and court officials for judicial acts.

The firm represented the City, as well as the City’s Municipal Court Judge, Administrator, and Prosecutor, with regard to the Plaintiff’s Complaint in which she alleged that the Municipal Court violated her rights by staying her criminal case pending the outcome of her state civil matter. Our firm filed a motion to dismiss in October 2024, seeking a judgment on the pleadings that the Plaintiff’s Complaint failed to state a valid cause of action due to the immunities afforded to judicial officials.

The Court agreed with the firm’s arguments that the Municipal Judge’s determination to stay the case was protected by the Judge’s absolute immunity. The Court found that the decision to stay a case is well within the authority of a court to manage its docket and is a measure performed by a judge in his or her official capacity. The Court noted the importance of judicial immunity, stating that it “serves to prevent judicial officers from being chilled by the constant threat of civil rights lawsuits for making controversial decisions.”

Judge Quraishi also determined that the Court Administrator was immune from suit due to the quasi-judicial immunity afforded to court officials, since scheduling cases is integral to the judicial process and the Court Administrator was following direction from the Judge and Prosecutor. The Court also determined that the Prosecutor was immune from suit since deferring the prosecution of Plaintiff’s criminal case was within the judicial phase of the criminal process to which immunity applies. Finally, the Court agreed that the City could not be liable, since the municipal body possesses no legal control over the judicial function of its municipal court.

Anthony P. Seijas, Partner of the Firm, and Gregory A. Randazzo, Counsel of the Firm, briefed and handled the case representing the City of Asbury Park and its Court Officials from its inception.