Hill v. Johnson (11th Cir. 2025): Judicial Immunity, Res Judicata, and Barton Doctrine in Takings Disputes

1. Introduction

In Jeffrey Lance Hill, Sr. v. Leandra G. Johnson, 11th Circuit No. 23-12231 (March 4, 2025), the court addressed the latest chapter in a two-decade dispute over the repair and maintenance of a farm reservoir in Columbia County, Florida. Plaintiff‐Appellant Jeffrey Hill sued:

Three state judges (Leandra Johnson, Gregory Parker, William Williams) for alleged wrongful injunctions, fines, and flooding orders;
Two private attorneys (Joel Foreman, Jennifer Springfield) for alleged malicious filings;
The Suwannee River Water Management District, Columbia County, the City of Lake City, and a court-appointed receiver (Michael Smallridge) for takings and related constitutional claims.

Hill argued that prior judgments were void, that state judges lacked jurisdiction, and that various takings, due‐process, equal‐protection, jury‐trial and excessive‐fine claims survived dismissal. The district court dismissed all ten counts—Counts I–IV on judicial immunity grounds, Counts V–IX under res judicata, and Count X for lack of subject‐matter jurisdiction under the Barton doctrine. Hill appealed.

2. Summary of the Judgment

The Eleventh Circuit affirmed in part and remanded in part. It held:

Judicial Immunity (Counts I–IV): Judges Johnson, Parker, and Williams were acting in their judicial capacity and had subject‐matter jurisdiction over Hill’s state‐court cases. They enjoy absolute immunity from §1983 money‐damages claims—even for alleged takings.
Res Judicata (Counts V–IX): Hill’s 2017 federal lawsuit against the same parties and arising from the same reservoir dispute was a final, preclusive judgment on the merits. It barred relitigation of the takings, due‐process, and excessive‐fine theories now reasserted.
Barton Doctrine (Count X): Smallridge, as receiver, enjoyed the protection of Barton v. Barbour. Hill’s failure to obtain leave from the Florida circuit court deprived the federal district court of jurisdiction. That claim must be dismissed without prejudice.
Supplemental Pleadings: The court did not abuse its discretion in denying leave to file further amendments, since any new allegations would remain barred by immunity, res judicata, or lack of jurisdiction.

3. Analysis

3.1 Precedents Cited

Stump v. Sparkman, 435 U.S. 349 (1978): Established that judges are immune from civil damages for judicial acts within their jurisdiction.
Simmons v. Conger, 86 F.3d 1080 (11th Cir. 1996): Set forth the two‐pronged test for §1983 judicial immunity (judicial capacity & absence of jurisdiction).
Sibley v. Lando, 437 F.3d 1067 (11th Cir. 2005): Identified factors to determine “judicial capacity.”
Dykes v. Hosemann, 776 F.2d 942 (11th Cir. 1985): Defined “clear absence of all jurisdiction” for immunity purposes.
Rooker v. Fid. Trust Co., 263 U.S. 413 (1923) & District of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983): Prohibited federal courts from reviewing final state‐court judgments (Rooker‐Feldman doctrine).
Barton v. Barbour, 104 U.S. 126 (1881): Held that a receiver cannot be sued without leave of the appointing court (Barton doctrine).

3.2 Legal Reasoning

Judicial Immunity: The court applied the Simmons two‐pronged test:

Judicial Capacity: All complained‐of acts—issuing injunctions, imposing fines, ordering drainage—were “normal judicial functions” in cases pending before the judges.
Jurisdictional Scope: Hill conceded state circuit courts had general subject‐matter jurisdiction over land, injunctive, and declaratory claims. No judge acted in the “clear absence of all jurisdiction.”

Res Judicata: Under federal common law, Hill’s 2017 suit (dismissed with prejudice) satisfied all four elements of claim preclusion:

Court of competent jurisdiction (Middle District of Florida).
Final judgment on the merits (dismissal with prejudice for failure to state a claim).
Same parties (City, County, District, Springfield, Foreman).
Same cause of action or operative nucleus of facts (reservoir takings and constitutional claims).

Barton Doctrine: The court held that the Florida circuit court’s appointment of Smallridge as receiver fell within Barton. Because Hill did not obtain leave from that state court before suing the receiver, the federal court lacked subject‐matter jurisdiction over Count X. The court also rejected Hill’s challenge to Judge Williams’s appointment: under Florida’s Constitution and statutes, the Chief Justice (and by delegation the chief circuit judge) may temporarily assign county judges to circuit‐court duty in all counties of the circuit.

3.3 Impact on Future Cases

This decision reinforces several enduring principles:

Judicial Immunity’s Breadth: Even constitutional takings or excessive fines claims against judges are barred if the acts were judicial and within jurisdiction.
Res Judicata’s Finality: Plaintiffs cannot evade preclusion by rebranding claims already litigated to finality.
Barton Doctrine’s Jurisdictional Role: Courts must enforce leave requirements before entertaining suits against receivers.
Validity of Temporary Judicial Assignments: Confirms Florida’s Chief Justice may reassign judges across counties, preserving the legitimacy of orders and appointments by such judges.

4. Complex Concepts Simplified

Judicial Immunity: A judge cannot be sued for money damages over official acts—even erroneous ones—so long as he or she had jurisdiction and was acting in a judicial role.
Res Judicata (Claim Preclusion): Once a court issues a final decision on the merits, the same parties may not bring the same claim or any claim arising from the same set of facts.
Rooker‐Feldman Doctrine: Federal district courts may not act as appellate courts over state‐court judgments; federal relief must be sought through the Supreme Court’s certiorari process.
Barton Doctrine: A special rule requiring permission from the court that appointed a receiver before lawsuits against that receiver may proceed.
Temporary Judicial Assignments in Florida: The state’s Chief Justice (or chief circuit judge by delegation) can assign a county judge to hear circuit‐court matters in any county within the circuit.

5. Conclusion

Hill v. Johnson stands as a comprehensive reaffirmation of foundational jurisdictional and procedural bars in federal litigation. The Eleventh Circuit underscored that

judges remain protected by absolute immunity even against takings claims;
once litigated to finality, claims cannot be repackaged to circumvent res judicata;
and receivers enjoy Barton protection unless the appointing court grants leave to sue.

By upholding these doctrines and clarifying the lawfulness of temporary judicial assignments, the court curtails repetitive litigation over the same operative facts and reinforces the stability of court‐appointed remedies.