Reaffirming Claim Preclusion and Judicial Immunity in Repetitive § 1983 Prisoner Litigation: Commentary on Lynn A. Padgett v. Petti et al. (3d Cir. 2025)

1. Introduction

The Third Circuit’s nonprecedential opinion in Lynn A. Padgett v. James Petti, et al., No. 24‑1332 (3d Cir. Nov. 18, 2025), illustrates how federal courts use longstanding doctrines—claim preclusion (res judicata), judicial immunity, and modern pleading standards—to manage repetitive pro se prisoner civil-rights actions arising from old criminal prosecutions.

Lynn A. Padgett, a Pennsylvania state prisoner, filed a 42 U.S.C. § 1983 action in 2023 alleging constitutional violations stemming from a 1997 criminal case (“Case II”) in which he had already been convicted and sentenced for sexual offenses. A substantially similar civil-rights action brought by Padgett in 2011, against overlapping defendants, had been dismissed with prejudice under 28 U.S.C. § 1915A(b)(1) for failure to state a claim. In 2023, Padgett tried again, this time adding the current District Attorney and the sentencing judge as defendants and pressing a theory of a broad “conspiracy” against him.

The District Court (M.D. Pa., Judge Conner) dismissed the 2023 complaint with prejudice at the § 1915A screening stage, adopting a Magistrate Judge’s recommendation that: (1) claims against the arresting officer and former District Attorney were barred by res judicata, (2) claims against the sentencing judge were barred by judicial immunity, and (3) amendment would be futile. Padgett appealed pro se.

The Third Circuit affirmed in a per curiam opinion. While formally “not precedential” under the Court’s Internal Operating Procedures, the decision is a clear and structured application of several important doctrines that frequently arise in prisoner civil-rights litigation:

When a prior § 1983 suit dismissed with prejudice under § 1915A(b)(1) precludes later suits involving the same events (claim preclusion);
The breadth of absolute judicial immunity and the tight statutory limits on injunctive relief against judges under § 1983;
The requirement of non-conclusory factual allegations to support conspiracy and supervisory liability claims under Ashcroft v. Iqbal;
The standard for denying leave to amend as futile at the screening stage.

2. Factual and Procedural Background

2.1 Underlying Criminal Cases

In 1997, Pennsylvania State Trooper James Petti arrested Padgett for sex offenses committed in Bradford County against multiple minors. Padgett confessed the same day and later pleaded guilty in the Bradford County Court of Common Pleas (BCCCP) to involuntary deviate sexual intercourse. This case was docketed as CP‑08‑CR‑0000768‑1997.

The day after the confession, Trooper Petti received a report that Padgett had also sexually abused another minor, this time a victim residing in neighboring Lycoming County. Padgett was charged in Bradford County (BCCCP) with several counts resulting from this abuse. That second prosecution is referred to by the Third Circuit as “Case II” and was docketed as CP‑08‑CR‑0000888‑1997.

Padgett ultimately pleaded guilty in Case II to one count of rape. Across the two cases, he received an aggregate sentence of 15 to 30 years’ imprisonment. The opinion notes that his attempts to challenge his convictions and sentence through other avenues have been unsuccessful.

2.2 The 2011 Federal Civil-Rights Action

In 2011, Padgett filed a pro se § 1983 complaint in the U.S. District Court for the Middle District of Pennsylvania. The defendants included:

Trooper James Petti (the arresting officer);
The Bradford County District Attorney’s Office;
Former Bradford County District Attorney Robert B. McGuinness (the DA at the time of Case II);
Padgett’s defense attorney in Case II.

That complaint asserted various claims related to the investigation and litigation of Case II. In May 2011, the District Court dismissed the complaint with prejudice under 28 U.S.C. § 1915A(b)(1) for failure to state a claim upon which relief may be granted. Padgett did not appeal.

The “with prejudice” dismissal is central: it functioned as a final judgment on the merits for purposes of later claim-preclusion analysis.

2.3 The 2023 Federal Civil-Rights Action

In 2023, Padgett filed a new pro se civil-rights complaint in the same federal district court. Again, he targeted events related to Case II and sought both injunctive relief and money damages. This time, he named:

Trooper James Petti;
Former DA Robert B. McGuinness;
Daniel J. Barrett, who later became Bradford County District Attorney and also serves as Prothonotary/Clerk of Courts;
Senior Judge Jeffrey A. Smith of the Bradford County Court of Common Pleas (the sentencing judge in Case II).

The opinion describes the 2023 complaint as “not a model of clarity,” but it identifies its core themes:

Padgett objected that Case II (involving a Lycoming County victim) was prosecuted and litigated in Bradford County;
He alleged a broad “conspiracy” among the defendants to violate his rights in connection with Case II;
He sought injunctive and monetary relief based on these assertions.

To the extent Padgett attempted to argue on appeal that his 2023 complaint was unrelated to Case II, the Third Circuit rejected that contention as “unpersuasive,” pointing to the complaint’s content.

2.4 The Magistrate Judge’s Report and District Court’s Decision

A U.S. Magistrate Judge screened the 2023 complaint under § 1915A and recommended dismissal with prejudice, reasoning, among other things:

Claim Preclusion (Res Judicata): Claims against Petti and McGuinness were barred because Padgett had previously sued them in 2011 based on the same events, and that earlier case ended in a dismissal with prejudice under § 1915A(b)(1).
Judicial Immunity: Claims against Judge Smith were barred by absolute judicial immunity for judicial acts performed within jurisdiction.
Futility of Amendment: Allowing Padgett to amend would be futile in light of these legal barriers and the nature of the allegations.

On January 23, 2024, Judge Conner overruled Padgett’s objections, adopted the report, and dismissed the complaint with prejudice under § 1915A(b)(1). Padgett appealed to the Third Circuit.

3. Summary of the Third Circuit’s Opinion

The Third Circuit exercised appellate jurisdiction under 28 U.S.C. § 1291 and reviewed the dismissal de novo (“plenary review”) pursuant to Durham v. Kelley, 82 F.4th 217, 223 (3d Cir. 2023). The panel also reiterated that it could affirm on any basis supported by the record (Murray v. Bledsoe, 650 F.3d 246, 247 (3d Cir. 2011) (per curiam)).

The Court affirmed the dismissal in full. Its principal holdings were:

Claims against Petti and McGuinness: Barred by claim preclusion (res judicata). The 2011 dismissal with prejudice under § 1915A(b)(1) was a final judgment on the merits, involved the same parties, and concerned the same cause of action (events surrounding Case II). Res judicata also barred claims Padgett could have raised in 2011, defeating his argument that some claims “accrued” later.
Claims against Judge Smith: Barred by absolute judicial immunity. The judge acted in his judicial capacity and not in a “clear absence of all jurisdiction.” The fact that the case was tried in Bradford County rather than Lycoming County implicated venue, not subject-matter jurisdiction, in light of Pennsylvania’s statewide criminal jurisdiction for courts of common pleas (Commonwealth v. Bethea, 828 A.2d 1066, 1074 (Pa. 2003)). Additionally, injunctive relief against Judge Smith was unavailable because § 1983 only authorizes such relief where a declaratory decree has been violated or declaratory relief is unavailable (42 U.S.C. § 1983; Larsen v. Senate of Pa., 152 F.3d 240, 249 (3d Cir. 1998)).
Claims against DA Barrett: Even assuming they were not precluded, they failed to state a claim under the plausibility standard. Padgett alleged only that Barrett joined and failed to stop a conspiracy; these were “naked assertion[s] devoid of further factual enhancement,” insufficient under Ashcroft v. Iqbal, 556 U.S. 662, 678–79 (2009). The Court agreed that amendment would be futile, citing LaSpina v. SEIU Pa. State Council, 985 F.3d 278, 291 (3d Cir. 2021).
Judicial Notice: Padgett’s request for the appellate court to take judicial notice of various items (including a legal conclusion, statements about the scope of his claims, and a disputed factual assertion about when he discovered evidence) was denied under the standard in Werner v. Werner, 267 F.3d 288, 295 (3d Cir. 2001). These were not “adjudicative facts” not subject to reasonable dispute.

The Court concluded that none of Padgett’s appellate arguments had merit and affirmed the District Court’s dismissal with prejudice. It declined to reach other alternative grounds for dismissal discussed by the Magistrate Judge.

4. Analysis of the Court’s Legal Reasoning

4.1 Screening Under 28 U.S.C. § 1915A and Appellate Review

Section 1915A requires federal courts to screen civil complaints filed by prisoners against governmental entities or employees and dismiss those that are frivolous, malicious, or fail to state a claim. The “failure to state a claim” standard mirrors Federal Rule of Civil Procedure 12(b)(6); courts apply the Twombly/Iqbal plausibility standard.

The Third Circuit’s reference to Durham v. Kelley underscores that it reviews such dismissals plenary—de novo—without deference to the District Court’s legal conclusions. Its citation to Murray v. Bledsoe confirms the well-settled principle that an appellate court may affirm on any ground supported by the record, including grounds different from those relied on below.

4.2 Claim Preclusion (Res Judicata) Against Petti and McGuinness

The panel’s analysis of claim preclusion (res judicata) relies on two earlier Third Circuit decisions: Duhaney v. Attorney General, 621 F.3d 340 (3d Cir. 2010), and In re Mullarkey, 536 F.3d 215 (3d Cir. 2008). The Court recites the now-standard three-part test for claim preclusion:

Res judicata, also known as claim preclusion, applies when there is “(1) a final judgment on the merits in a prior suit involving (2) the same parties or their privies and (3) a subsequent suit based on the same cause of action.” This doctrine “bars not only claims that were brought in a previous action, but also claims that could have been brought.”

Applying that test, the Court had little difficulty concluding that res judicata barred Padgett’s 2023 claims against Petti and McGuinness:

Final judgment on the merits: The 2011 case was dismissed with prejudice for failure to state a claim under § 1915A(b)(1). Such a dismissal operates as an adjudication on the merits for claim-preclusion purposes. It is not a mere procedural dismissal; it resolves the substantive sufficiency of the claims.
Same parties: Petti and McGuinness were defendants in both the 2011 and 2023 cases. The “same parties or their privies” element was directly satisfied as to them.
Same cause of action: Both suits arose from the same nucleus of operative facts—the investigation and prosecution of Case II. Although the precise legal labels or additional factual details may have shifted, that does not create a new cause of action for res judicata purposes. The doctrine focuses on the underlying events, not the creative repackaging of theories.

The Court also emphasized a critical and often misunderstood dimension of res judicata: it bars not just claims that were brought, but also those that could have been brought in the earlier action. This directly defeats Padgett’s argument that some of his 2023 claims did not accrue until years after the 2011 case ended. The panel described that argument as having “no merit.”

Implicit in the Court’s conclusion is the determination that Padgett’s 2023 allegations arose from the same transactional core as the 2011 case. New legal theories, evolving rhetoric about a “conspiracy,” or newly discovered evidence related to the same events typically cannot evade res judicata once the first action has resulted in a final judgment on the merits.

4.3 Judicial Immunity and the Limits of Relief Against Judge Smith

4.3.1 Absolute Judicial Immunity

The panel’s treatment of judicial immunity rests on two key authorities:

Azubuko v. Royal, 443 F.3d 302, 303 (3d Cir. 2006) (per curiam): “A judicial officer in the performance of his duties has absolute immunity from suit and will not be liable for his judicial acts.”
Stump v. Sparkman, 435 U.S. 349, 356–57 (1978): establishing that judges are immune for judicial acts unless they act in the “clear absence of all jurisdiction.”

The doctrine distinguishes between:

Judicial acts (e.g., presiding over trials, ruling on motions, sentencing), which are protected; and
Non-judicial acts (e.g., administrative or personal actions outside the judge’s judicial function), which may not be covered.

Padgett challenged Judge Smith’s role in trying and sentencing him in Bradford County instead of Lycoming County. The panel readily concluded these were quintessential judicial acts taken in the course of presiding over a criminal case in the Court of Common Pleas.

4.3.2 “Clear Absence of All Jurisdiction” and the Venue Argument

The only recognized exception to absolute judicial immunity relevant here is where a judge acts in the “clear absence of all jurisdiction.” Padgett attempted to fit within this exception by arguing that Judge Smith lacked jurisdiction because Case II should have been brought in Lycoming County, where the victim resided.

The panel rejected this argument, relying on Commonwealth v. Bethea, 828 A.2d 1066, 1074 (Pa. 2003), which held:

[A]ll courts of common pleas have statewide subject matter jurisdiction in cases arising under the Crimes Code.

Thus, any question about whether Bradford County or Lycoming County was the correct location for trial implicated venue, not subject-matter jurisdiction. Venue errors, even serious ones, do not equate to a “clear absence of all jurisdiction.” So long as the court has subject-matter jurisdiction over the type of case (here, a criminal prosecution under the Pennsylvania Crimes Code) and personal jurisdiction over the defendant, judicial acts undertaken in that case are protected by absolute immunity.

Accordingly, Judge Smith did not act in the “clear absence of all jurisdiction,” and the exception did not apply. As a result, Padgett’s damages claims against Judge Smith were barred in full.

4.3.3 Injunctive Relief Against Judges Under § 1983

Judicial immunity primarily bars suits for damages. Historically, plaintiffs sometimes attempted to circumvent immunity by requesting purely prospective relief, such as injunctions. Congress constrained that workaround in 1996, when it amended 42 U.S.C. § 1983 to state:

[I]n any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable.

The panel, citing Larsen v. Senate of Pennsylvania, 152 F.3d 240, 249 (3d Cir. 1998), applied this statutory limitation. Padgett had not alleged that:

a declaratory decree had been violated; or
declaratory relief was unavailable to him.

Absent one of those narrow circumstances, § 1983 itself bars injunctive relief against a judge for judicial acts. Therefore, both damages and injunctive relief claims against Judge Smith failed as a matter of law.

4.4 Pleading Standards and Conspiracy Allegations Against DA Barrett

Unlike Petti and McGuinness, District Attorney Daniel Barrett had not been a defendant in the 2011 lawsuit. The Magistrate Judge had apparently recommended that res judicata also bar claims against him (likely on privity or same-cause-of-action grounds), but the Third Circuit resolved his liability on a different basis: failure to state a claim under modern pleading standards.

The Court “assum[ed] for the sake of argument” that res judicata did not bar the claims against Barrett, but found them deficient under Iqbal. The 2023 complaint alleged that Barrett:

joined the other defendants’ “conspiracy” against Padgett; and
failed to put a stop to that conspiracy.

However, the Court found that Padgett had failed to allege:

any specific, plausible facts indicating when, how, or why Barrett supposedly joined a conspiracy;
what concrete actions Barrett allegedly took (or failed to take) that violated Padgett’s rights.

Quoting Ashcroft v. Iqbal, 556 U.S. 662 (2009), the panel reiterated that a complaint must:

“state a claim to relief that is plausible on its face”; and
include factual allegations that permit the court to infer more than “the mere possibility of misconduct.”

“Naked assertion[s] devoid of further factual enhancement” are insufficient. Conclusory allegations of a “conspiracy,” without concrete factual detail—such as specific meetings, communications, or acts in furtherance—do not meet the plausibility threshold.

In short, even if res judicata did not apply to Barrett, the complaint still failed at the Rule 12(b)(6)/§ 1915A screening stage, and the Court agreed with the District Court that amendment would be futile.

4.5 Futility of Amendment and Denial of Leave to Amend

Under Federal Rule of Civil Procedure 15(a), leave to amend should be “freely give[n] when justice so requires.” But courts routinely deny leave where amendment would be futile—i.e., where even an amended complaint could not survive a motion to dismiss.

The panel cited LaSpina v. SEIU Pennsylvania State Council, 985 F.3d 278, 291 (3d Cir. 2021), for the principle that “leave to amend need not be granted if amendment would be futile.” Given:

the claim-preclusion bar to claims against Petti and McGuinness;
absolute judicial immunity and statutory limits on injunctive relief for claims against Judge Smith; and
the wholly conclusory nature of the allegations against Barrett, coupled with the absence of any indication that more concrete facts could be pled;

the Court concluded that the District Court did not err in dismissing with prejudice without allowing further amendment.

4.6 Judicial Notice on Appeal

Padgett’s opening brief in the Court of Appeals included a “Request for Judicial Notice.” The panel, citing Werner v. Werner, 267 F.3d 288, 295 (3d Cir. 2001), reiterated the standard:

A court may take judicial notice of an adjudicative fact if that fact is not subject to reasonable dispute.

The items Padgett wanted judicially noticed were:

a legal conclusion;
two statements apparently delineating the scope of his claims; and
a contested assertion about when he discovered evidence allegedly supporting his action.

None of these is the kind of indisputable, objective fact suitable for judicial notice. Legal conclusions and subjective characterizations of claims are inherently disputable, just as contested timeline assertions may require evidentiary development rather than judicial notice. The panel therefore denied the request and any other relief Padgett sought on appeal.

5. Discussion of Key Precedents Cited

5.1 Durham v. Kelley, 82 F.4th 217 (3d Cir. 2023)

Durham confirms that the Third Circuit reviews dismissals for failure to state a claim under § 1915A de novo. The panel’s reliance on this case underscores that no deference is given to the District Court’s legal determinations at the screening stage; the appellate court independently assesses whether the complaint states a plausible claim.

5.2 Murray v. Bledsoe, 650 F.3d 246 (3d Cir. 2011) (per curiam)

Murray is often cited for the principle that an appellate court can affirm a lower court’s judgment “on any basis supported by the record,” even if that basis differs from the reasoning used below. Here, it allowed the Third Circuit to structure its reasoning around the clearest and most straightforward grounds—res judicata, judicial immunity, and pleading standards—without addressing every alternative rationale from the Magistrate Judge’s report.

5.3 Duhaney v. Attorney General, 621 F.3d 340 (3d Cir. 2010), and In re Mullarkey, 536 F.3d 215 (3d Cir. 2008)

These cases articulate the modern Third Circuit test for claim preclusion, adopted wholesale in this opinion. Duhaney, quoting Mullarkey, clarifies:

Res judicata applies when there is: (1) a final judgment on the merits; (2) involving the same parties or their privies; and (3) a subsequent suit based on the same cause of action;
The doctrine bars claims that were or “could have been” brought in the prior action.

This standard underpins the Court’s conclusion that Padgett cannot revive or reframe Case II-related claims against Petti and McGuinness in 2023 after losing on the merits in 2011.

5.4 Azubuko v. Royal, 443 F.3d 302 (3d Cir. 2006) (per curiam) and Stump v. Sparkman, 435 U.S. 349 (1978)

Azubuko restates the rule of absolute judicial immunity in the Third Circuit: judicial officers are immune from suit for judicial acts undertaken in their official capacity. Stump is the foundational Supreme Court authority that delineates the scope of this immunity and recognizes the “clear absence of all jurisdiction” exception. Together, they justify shielding Judge Smith from suit for his role in Padgett’s criminal case.

5.5 Commonwealth v. Bethea, 828 A.2d 1066 (Pa. 2003)

Bethea establishes that Pennsylvania courts of common pleas have statewide subject-matter jurisdiction over criminal cases under the Crimes Code. This is crucial to the panel’s rejection of Padgett’s attempt to transform a venue complaint (trial in the “wrong” county) into a jurisdictional defect that might pierce judicial immunity. Because the Court of Common Pleas in Bradford County had subject-matter jurisdiction, Judge Smith did not act outside his jurisdiction.

5.6 Larsen v. Senate of Pennsylvania, 152 F.3d 240 (3d Cir. 1998)

Larsen interprets the 1996 amendment to § 1983 that sharply limits injunctive relief against judges. It confirms that plaintiffs may not obtain injunctions against judges for judicial acts unless they can show a violated declaratory decree or the unavailability of declaratory relief. This decision, combined with the statutory text of § 1983, forecloses Padgett’s injunctive claims against Judge Smith.

5.7 Ashcroft v. Iqbal, 556 U.S. 662 (2009)

is the cornerstone of contemporary federal pleading standards. It requires that complaints:

Contain sufficient factual matter, accepted as true, to “state a claim to relief that is plausible on its face”; and
Provide more than labels, conclusions, or formulaic recitations of elements.

The Third Circuit applies Iqbal to find that Padgett’s allegations against DA Barrett—asserting only his participation in and failure to stop a conspiracy—are too conclusory and devoid of factual enhancement to survive screening.

5.8 LaSpina v. SEIU Pennsylvania State Council, 985 F.3d 278 (3d Cir. 2021)

LaSpina confirms that district courts need not grant leave to amend where amendment would be futile—i.e., where the amended complaint would still fail to state a claim. By citing LaSpina, the panel endorses the District Court’s decision to dismiss with prejudice at the screening stage, given the insurmountable legal obstacles (preclusion, immunity, lack of plausibility).

5.9 Werner v. Werner, 267 F.3d 288 (3d Cir. 2001)

Werner provides the standard for judicial notice: a court may notice an adjudicative fact only if it is not subject to reasonable dispute. The panel uses this authority to deny Padgett’s attempt to have the Court take notice of disputed factual assertions and legal characterizations—matters wholly unsuitable for judicial notice.

6. Simplifying the Key Legal Concepts

6.1 Claim Preclusion (Res Judicata)

Res judicata, or claim preclusion, prevents a party from re-litigating a claim that has already been decided or that could have been raised in an earlier action. It serves finality and efficiency by ensuring that parties get one full and fair opportunity to litigate a set of facts, not endless retries under new labels.

To apply, three conditions must be met:

There was a final judgment “on the merits” in the earlier case (here, the 2011 dismissal with prejudice under § 1915A(b)(1));
The earlier and later cases involve the same parties or their privies (here, Padgett vs. Petti and McGuinness);
The later case is based on the same “cause of action” (essentially, the same underlying events—here, the investigation and prosecution in Case II).

Once those conditions are satisfied, the plaintiff cannot bring new suits over the same events, whether by stating new legal theories or adding factual details that could have been asserted the first time.

6.2 Judicial Immunity

Judicial immunity is an absolute immunity that protects judges from being sued for damages for their judicial acts, even if those acts are alleged to have been mistaken, malicious, or illegal. The policy behind it is to allow judges to decide cases independently, without fear of personal civil liability.

Two important limitations:

The act must be “judicial” in nature (e.g., presiding over a hearing, issuing an order, sentencing), not administrative or purely personal;
The judge must not have acted in the “clear absence of all jurisdiction.” Mere legal errors or even serious procedural irregularities do not defeat immunity if the court had subject-matter jurisdiction over the type of case.

In Padgett’s case, trying and sentencing him in Case II were plainly judicial acts, and the Court of Common Pleas had statewide criminal jurisdiction under Pennsylvania law. Judicial immunity therefore applies.

6.3 Subject-Matter Jurisdiction vs. Venue

Padgett’s argument that Judge Smith lacked jurisdiction because the victim resided in another county confuses two different concepts:

Subject-matter jurisdiction is the court’s authority to hear a particular type of case (e.g., criminal cases under the Crimes Code);
Venue is the specific geographic location where a case should be tried within a jurisdiction.

In Pennsylvania, all courts of common pleas have statewide subject-matter jurisdiction over Crimes Code cases (Bethea). Whether a particular county is the “right” place to bring the case affects venue, not jurisdiction. Errors in venue do not strip a court of subject-matter jurisdiction and thus do not defeat judicial immunity.

6.4 Injunctive Relief Against Judges Under § 1983

After 1996, § 1983 sharply limits injunctive relief against judicial officers. A plaintiff may not obtain an injunction against a judge for judicial acts unless:

A “declaratory decree was violated”; or
“Declaratory relief was unavailable.”

Unless one of those narrow conditions is met, courts must deny requests for injunctions seeking to control or undo a judge’s decisions in his or her judicial capacity. Padgett did not meet these conditions, so injunctive relief was unavailable.

6.5 The Plausibility Pleading Standard (Iqbal)

Under Iqbal, a complaint must provide enough factual detail to allow a court to draw a reasonable inference that the defendant is liable for the alleged misconduct. Mere:

labels (e.g., “conspiracy”);
recitation of legal elements; or
conclusory statements (“X violated my rights”);

are insufficient. Courts disregard such conclusory statements and look to the remaining factual allegations. If what remains is too sparse or vague to make liability plausible, the complaint is dismissed.

For conspiracy claims specifically, plaintiffs must usually allege:

who agreed with whom;
the nature of the agreement;
roughly when and where the agreement was made; and
what each conspirator did to further the conspiracy.

Padgett’s complaint lacked this level of detail with respect to DA Barrett.

6.6 Judicial Notice

Judicial notice is a mechanism that allows courts to recognize certain facts as true without requiring formal proof, but only if the fact is:

not subject to reasonable dispute; and
either generally known within the jurisdiction or easily verifiable from reliable sources.

Examples include the date of a public holiday or the fact that a court docket entry exists. Courts will not take judicial notice of contested historical facts, parties’ interpretations of evidence, or legal conclusions. Padgett’s attempted use of judicial notice to establish key points about his claims and evidence discovery fell outside these limits and was properly rejected.

6.7 Futility of Amendment

Even though courts generally give pro se litigants some leeway and often allow at least one opportunity to amend, they may deny leave to amend when it is clear that:

a legal bar (such as res judicata or absolute immunity) would still apply; or
the pleading deficiencies (e.g., conclusory conspiracy allegations) cannot be cured by additional factual detail realistically available to the plaintiff.

In that event, amendment is deemed “futile,” and dismissal with prejudice is appropriate.

7. Impact and Broader Significance

Although explicitly labelled “not precedential” under the Third Circuit’s Internal Operating Procedure 5.7, the Padgett opinion is instructive on several recurring issues in prisoner civil-rights litigation and § 1983 practice generally.

7.1 Reinforcing the Preclusive Effect of Prior § 1915A Dismissals

The decision underscores that a dismissal with prejudice under § 1915A(b)(1) constitutes a final judgment on the merits for claim-preclusion purposes. Prisoners who file repetitive suits challenging the same criminal proceedings or underlying events cannot avoid res judicata by:

adding or rephrasing allegations;
emphasizing different legal theories; or
asserting that they discovered “new evidence” years later, absent a genuinely new wrong.

District courts within the Third Circuit can rely on this reasoning when screening successive complaints arising from the same criminal cases or investigations.

7.2 Clarifying the Limits of Attacks on Venue Through § 1983

By tying Padgett’s Bradford vs. Lycoming County argument to Bethea, the Court clarifies that Pennsylvania’s statewide criminal jurisdiction for courts of common pleas makes venue errors non-jurisdictional for immunity purposes. Prisoner-plaintiffs cannot pierce judicial immunity by characterizing venue disputes as jurisdictional defects.

7.3 Strengthening the Shield of Judicial Immunity and § 1983’s Injunctive Relief Restriction

The opinion reinforces that:

Judges enjoy broad immunity from § 1983 damages suits for acts taken in their judicial capacity; and
Post-1996, § 1983 offers only very narrow pathways for injunctive relief against judges.

This guidance will discourage attempts to relitigate state-court criminal proceedings indirectly by suing trial judges in federal court for damages or injunctions, especially in the absence of a violated declaratory decree or an unavailability of declaratory relief.

7.4 Emphasizing the Need for Specific, Non-Conclusory Conspiracy Allegations

The Court’s application of Iqbal to dismiss the claims against DA Barrett highlights the high bar for conspiracy and supervisory-liability allegations. Merely asserting that a prosecutor “joined” a conspiracy or “failed to stop” wrongdoing, without factual detail, will not suffice.

This is particularly important in the prisoner-litigation context, where conspiracy allegations are frequently used to rope in additional state actors (current officials, supervisors, or later-appointed prosecutors) into already-litigated disputes.

7.5 Managing Repetitive Prisoner Litigation and Conserving Judicial Resources

The case showcases how federal courts implement the Prison Litigation Reform Act (PLRA) framework—of which § 1915A is a key component—to screen complaints early and dismiss meritless or precluded actions with prejudice, thereby conserving judicial resources.

At the same time, the Court remains doctrinally faithful: it carefully applies established res judicata, judicial immunity, and pleading standards instead of resorting to broad statements about frivolousness or abuse of process.

8. Conclusion

Lynn A. Padgett v. Petti offers a concise yet layered application of several core doctrines in federal civil-rights litigation:

Claim Preclusion: A prior § 1915A dismissal with prejudice based on failure to state a claim has full res judicata effect, barring later suits against the same defendants over the same underlying events, including claims that could have been brought earlier.
Judicial Immunity: Judges are absolutely immune from damages for judicial acts taken within their subject-matter jurisdiction. Venue disputes do not create a “clear absence of all jurisdiction,” and post-1996 § 1983 sharply limits even injunctive relief against judges.
Pleading Standards: Under Iqbal, conclusory allegations of conspiracy or supervisory liability, without concrete factual detail, are insufficient to state a claim, even when pled by a pro se prisoner.
Futility of Amendment: Courts may dismiss with prejudice at the screening stage when res judicata, immunity, and lack of plausible factual content render amendment futile.
Judicial Notice: Appellate courts will not use judicial notice to adopt disputed facts, legal conclusions, or subjective characterizations contained in briefs.

While nonprecedential, the opinion provides a clear roadmap for lower courts and litigants dealing with repetitive § 1983 challenges to long-concluded criminal cases. It reinforces the finality of earlier judgments, the breadth of judicial immunity, and the strictures of modern pleading doctrine, thereby contributing to a stable and predictable framework for adjudicating prisoner civil-rights claims in the Third Circuit.