Frazier v. Prince George’s County: No Article III Adverseness to Sitting Judges and No Quasi-Judicial Immunity for Municipalities in § 1983 Actions

Introduction

In Robert Frazier v. Prince George’s County, No. 24-1380 (4th Cir. June 18, 2025), the United States Court of Appeals for the Fourth Circuit tackled two recurrent questions in civil-rights litigation against state actors:

Whether sitting state judges can be defendants in a federal suit challenging the constitutionality of their adjudicative conduct; and
Whether a county may invoke “quasi-judicial” immunity when sued under 42 U.S.C. § 1983.

The plaintiffs—nine current or former pre-trial detainees—allege that their continued incarceration under Prince George’s County’s two-phase bail-review system violates the Due Process Clause and Maryland law. They sued both the County and eleven state-court judges, seeking damages, declaratory relief, and an injunction. The district court dismissed all claims, holding that both sets of defendants enjoyed absolute or quasi-judicial immunity and that no meaningful declaratory relief could be fashioned.

Judge Heytens, writing for a unanimous panel, vacated the judgment as to the judges (for want of subject-matter jurisdiction), reversed the dismissal of all claims against the County, and remanded with instructions. The decision clarifies the scope of Article III “adverseness,” re-affirms that municipalities have no immunity defenses in § 1983 suits, and revives the claims of seven plaintiffs previously deemed moot.

Summary of the Judgment

Judicial defendants: Dismissed without prejudice for lack of Article III case-or-controversy. Because the judges acted only in an adjudicative capacity, they are not “adverse” litigants. The district court erred in reaching immunity; it lacked jurisdiction to do so.
County defendant: Dismissal reversed. Supreme Court precedent makes clear that municipalities cannot assert absolute, qualified, or quasi-judicial immunity under § 1983. Alternative defenses must be addressed on remand.
Previously released plaintiffs: Their claims for damages remain live; injunctive or declaratory relief may also survive for some. The district court’s earlier dismissal for mootness was incorrect.
Discovery quashing order: Left for reconsideration on remand because the posture of the judges has changed from party to potential non-party witnesses.

Analysis

A. Precedents Cited and Their Influence

Whole Woman’s Health v. Jackson, 595 U.S. 30 (2021) – Established that judges and clerks who act solely in an adjudicative role are not adverse parties for Article III purposes.
Muskrat v. United States, 219 U.S. 346 (1911) – Early articulation of the “adverseness” requirement.
Reule v. Jackson, 114 F.4th 360 (5th Cir. 2024) and Lindke v. Tomlinson, 31 F.4th 487 (6th Cir. 2022) – Circuit authority applying Whole Woman’s Health to bar suits against judges performing adjudicative functions.
Leatherman v. Tarrant County, 507 U.S. 163 (1993) and Owen v. City of Independence, 445 U.S. 622 (1980) – Supreme Court holdings that municipalities enjoy no immunity in § 1983 litigation.
Monell v. New York City Dep’t of Social Services, 436 U.S. 658 (1978) – Limits municipal liability to actions taken pursuant to a policy, custom, or practice.
Other supporting cases: Buckley v. Fitzsimmons, 509 U.S. 259 (1993); Briscoe v. LaHue, 460 U.S. 325 (1983); Consumers Union, 446 U.S. 719 (1980); Fourth Circuit decisions in Gibson v. Goldston and Owens v. Baltimore City SAO.

B. Court’s Legal Reasoning

Article III Adverseness
• Federal jurisdiction requires a concrete dispute between adverse parties.
• Judges here merely performed statutorily required bail-review functions; they did not enforce policy.
• Any grievance with a judge’s bail decision is remediable through state habeas or appellate review, not a collateral federal civil-rights suit.
• Therefore, the district court lacked jurisdiction to adjudicate claims against the judges and should have dismissed without prejudice.
Municipal Liability and Immunity
• The Supreme Court has consistently rejected immunity defenses for municipalities.
• “Quasi-judicial immunity” is a doctrine for individuals, not entities.
• The district court conflated the functional-approach analysis for individuals with the separate Monell framework for municipalities.
• Consequently, dismissal of County claims was error.
Mootness and Standing of Released Plaintiffs
• Damages provide continuing live controversy even after release.
• Three plaintiffs still in custody when suit began likely retain standing for equitable relief under Gerstein and Riverside precedents.
• The district court’s contrary ruling was vacated.

C. Impact of the Judgment

On suits against state judges: Reinforces a growing post-Whole Woman’s Health line that sitting judges are almost never proper § 1983 defendants for decisions made from the bench. Plaintiffs must seek appellate or habeas remedies rather than collateral § 1983 relief.
On municipal defenses: Closes the door (at least within the Fourth Circuit) on creative attempts to cloak local governments with “quasi-judicial” or similar immunities. Future municipal defendants must litigate on Monell grounds, not immunity.
On pre-trial detention litigation: Keeps open a pathway for detainees to challenge county-level policies and obtain damages or structural relief without suing judges. Encourages clearer record-keeping of policies within pre-trial services divisions.
Procedure in the district courts: Reminds lower courts to address jurisdictional obstacles before reaching immunities or merits and to avoid premature mootness rulings when damages are sought.

Complex Concepts Simplified

Article III “Adverseness” – Federal courts can decide only genuine disputes between parties with opposing interests. A neutral judge who merely decides cases is not “adverse” to the litigants who appear before her.
Absolute vs. Qualified vs. Quasi-Judicial Immunity – Doctrines shielding individual officials from damages when acting in certain roles (e.g., judges, prosecutors). “Quasi-judicial” extends to non-judges performing purely judicial tasks. These immunities never apply to municipalities.
Monell Liability – A city or county is liable under § 1983 only when the alleged constitutional violation implements or executes an official “policy or custom.” Respondeat superior does not apply.
Dismissal “without prejudice” – The plaintiff may re-file because the court has not reached the merits; contrast with “with prejudice,” which ends the claim forever.
Judgment on the Pleadings (Rule 12(c)) – A procedural vehicle, similar to a motion to dismiss, testing the legal sufficiency of the pleadings alone.
Mootness vs. Standing – Standing looks at circumstances when the complaint was filed; mootness considers later events that might extinguish the controversy. Damage claims rarely become moot.

Conclusion

Frazier v. Prince George’s County reshapes litigation strategy in the Fourth Circuit:

It cements the principle that sitting judges, when acting adjudicatively, are outside the reach of federal § 1983 suits for want of Article III controversy.
It simultaneously re-affirms that counties and cities may never assert quasi-judicial or other immunity defenses—liability turns on Monell, not immunity.
By reinstating the claims of detainees already released, the court underscores that damages remain a potent remedy and preserve live controversies.

Going forward, civil-rights plaintiffs challenging local criminal-justice practices must direct equitable claims toward municipalities (or executive officials) and seek appellate or habeas review for judicial missteps. Municipal defendants, for their part, must confront the merits of their customs and policies without the shield of judicial-style immunity.