Reaffirming Sua Sponte Claim Preclusion and Judicial Immunity: Third Circuit Affirms Dismissal of Repeat Civil-Rights Suit in Ouaziz v. Murphy

Introduction

In this non-precedential per curiam decision, the United States Court of Appeals for the Third Circuit affirmed the dismissal, with prejudice, of a serial civil-rights complaint brought by pro se appellant Bouazza Ouaziz against a broad set of state, county, and judicial actors, including the Governor of New Jersey and various officials within New Jersey’s Department of Human Services and Hudson County agencies. The claims arose from a protracted domestic history involving Mr. Ouaziz’s marriage and divorce from Noura Elghazani and related state proceedings, including DNA testing and child-support matters.

The key issues before the Court were:

Whether claim preclusion (res judicata) barred a second federal action that substantially overlapped with a prior action dismissed and affirmed on appeal;
Whether the District Court could raise res judicata sua sponte;
Whether allegations of a new or “another conspiracy” against additional defendants could avoid preclusion or judicial immunity;
Whether the complaint otherwise failed to state a plausible claim under the Twombly/Iqbal standard and Rule 8;
Whether the District Court abused its discretion in denying reconsideration.

The panel (Judges Bibas, Freeman, and Nygaard) held that claim preclusion applies because the second action duplicated the earlier case’s facts, parties (or their privies), and causes of action; that raising res judicata sua sponte was not reversible error; that judicial immunity barred the “another conspiracy” claims targeting judges; and that, in any event, the complaint failed to state a plausibly pleaded claim. The Court also noted the appellant forfeited review of certain default-judgment issues by not briefing them on appeal.

Summary of the Opinion

The Third Circuit affirmed the District Court’s dismissal of Mr. Ouaziz’s 2023 complaint, concluding:

Claim Preclusion: The complaint was “essentially the same” as the prior federal case—overlapping causes of action and an identical factual nucleus tied to the appellant’s relationship and divorce—thus barred by res judicata under Davis v. Wells Fargo and GAMBOCZ v. YELENCSICS.
Sua Sponte Preclusion: The District Court’s raising of res judicata on its own initiative did not constitute reversible error, consistent with ARIZONA v. CALIFORNIA.
Judicial Immunity: To the extent the appellant asserted “another conspiracy” involving judicial officers, those claims were barred by absolute judicial immunity under FIGUEROA v. BLACKBURN.
Pleading Deficiencies: Even apart from preclusion and immunity, the complaint failed to state any plausible claim, echoing the same defects identified in the appellant’s prior appeal (Ouaziz v. City of Jersey City). The panel affirmed on that alternative ground as well, invoking the rule that an appellate court may affirm on any basis supported by the record (MURRAY v. BLEDSOE).
Other Issues: The Court did not reach the District Court’s statute-of-limitations ruling because the above grounds were dispositive. It also deemed certain challenges (e.g., default-judgment questions) forfeited for failure to brief them on appeal (In re Wettach).

Analysis

Precedents Cited and Their Role

Claim-Preclusion Framework:
- Davis v. Wells Fargo, 824 F.3d 333 (3d Cir. 2016): The panel quoted the familiar tripartite test for res judicata—(1) a final judgment on the merits; (2) same parties or their privies; and (3) a subsequent suit based on the same cause of action, including claims that could have been brought in the prior action. The Court applied this test to conclude the successive actions were, in substance, the same dispute.
- GAMBOCZ v. YELENCSICS, 468 F.2d 837 (3d Cir. 1972): The panel relied on Gambocz to underscore that claim preclusion may extend to new defendants when there is a “close or significant relationship between successive defendants.” This defeated the appellant’s strategy of adding nominally “new” defendants to repackage the same core allegations.
Sua Sponte Preclusion:
- ARIZONA v. CALIFORNIA, 530 U.S. 392 (2000): Cited to support that a court may raise res judicata on its own where appropriate. The panel concluded there was no reversible error in the District Court’s doing so here.
Judicial Immunity:
- FIGUEROA v. BLACKBURN, 208 F.3d 435 (3d Cir. 2000): Quoted for the principle that judges retain immunity for judicial acts even if erroneous, malicious, or in excess of authority, unless performed in the “clear absence of all jurisdiction.” This foreclosed the appellant’s “another conspiracy” theory against judicial officers.
Pleading Standards and Review:
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) and Bell Atl. Corp. v. Twombly, 550 U.S. 544 (2007): Reiterated the plausibility standard—complaints must contain sufficient factual matter to state a claim on which relief can be granted.
- Smith & Wesson Brands, Inc. v. Attorney General of N.J., 105 F.4th 67 (3d Cir. 2024) and Rivera v. Monko, 37 F.4th 909 (3d Cir. 2022): Cited for de novo (plenary) review of dismissals under Rule 12(b)(6).
- Max’s Seafood Cafe ex rel. Lou‑Ann, Inc. v. Quinteros, 176 F.3d 669 (3d Cir. 1999): Cited for the abuse-of-discretion standard governing denials of reconsideration.
- MURRAY v. BLEDSOE, 650 F.3d 246 (3d Cir. 2011) (per curiam): Invoked to affirm on “any basis supported by the record,” enabling the panel to uphold dismissal on preclusion, immunity, and plausibility grounds.
- Ouaziz v. City of Jersey City, No. 22‑3385, 2023 WL 7001846 (3d Cir. Oct. 24, 2023): The panel referenced its prior ruling that the earlier complaint was “convoluted and difficult to understand” and failed to provide a clear narrative of factual and legal bases. That history informed both the res judicata ruling and the alternative conclusion that the current complaint also failed to state a plausible claim.
Appellate Jurisdiction and Forfeiture:
- 28 U.S.C. § 1291 and UNITED STATES v. STUDIVANT, 529 F.2d 673, 674 n.2 (3d Cir. 1976): Confirmed appellate jurisdiction over the final judgment and related orders.
- In re Wettach, 811 F.3d 99 (3d Cir. 2016): Applied for the principle that issues not developed in the opening brief are forfeited on appeal.

Legal Reasoning

The Court’s reasoning proceeded in three interconnected steps.

Comprehensive Overlap Triggered Claim Preclusion.
After comparing the 2023 complaint to the 2022 action, the District Court found, and the Third Circuit agreed, that the allegations, parties, and causes of action were materially the same, all flowing from the same domestic and family-court-related events. This satisfied the “same cause of action” element under Davis. The panel also endorsed the District Court’s determination that the parties were the same or in privity, and it relied on Gambocz to hold that even newly named defendants could be subject to claim preclusion where a “close or significant relationship” existed between successive defendants. The prior dismissal—affirmed on appeal—constituted the requisite final judgment for preclusion purposes as applied by the panel.
Sua Sponte Assertion of Preclusion Was Proper.
The appellant argued it was error for the District Court to raise res judicata on its own. The panel rejected that contention, citing ARIZONA v. CALIFORNIA to confirm that a court may, in appropriate circumstances, invoke preclusion sua sponte. No reversible error occurred here.
Judicial Immunity and Plausibility Failures Disposed of Any Residual Claims.
The appellant’s effort to avoid preclusion by alleging “another conspiracy” against new (primarily judicial) actors failed because those claims targeted judges performing judicial acts, who are absolutely immune unless acting in the clear absence of jurisdiction (Figueroa). The panel further held that, even if some defendants were not shielded by immunity, the complaint was independently subject to dismissal because it did not state any plausible claim under Iqbal/Twombly. This conclusion mirrored the deficiencies identified in the earlier Ouaziz appeal and provided an alternative, record-supported ground for affirmance (Murray).

Finally, because preclusion, immunity, and plausibility resolved the appeal, the panel declined to reach the statute-of-limitations ruling. It also noted that challenges to default-judgment issues were forfeited due to inadequate briefing (In re Wettach).

Impact and Practical Implications

Although designated “NOT PRECEDENTIAL” under Third Circuit I.O.P. 5.7, this decision meaningfully reinforces several practical points for litigants and trial courts:

Repeat Litigation Will Be Swiftly Precluded: Refiling substantially similar suits after an adverse federal judgment—particularly by adding closely related defendants or retitling allegations as an “another conspiracy”—will not evade claim preclusion in the Third Circuit.
Sua Sponte Gatekeeping Is Permissible: District courts may raise res judicata on their own initiative when the record makes preclusion apparent, promoting efficient docket management and preventing vexatious relitigation.
Judicial Immunity Remains Robust: Allegations of malice, error, or conspiratorial motives do not pierce absolute judicial immunity for judicial acts performed within jurisdiction.
Pleading Standards Apply Fully to Pro Se Litigants: Even generously construed, pro se complaints must present a coherent, plausible narrative linking facts to specific legal claims. Conclusory, sprawling, or disorganized pleadings will not survive.
Appellate Forfeiture Is Real: Issues not developed in an appellant’s opening brief are forfeited, including procedural gambits like default-judgment challenges.

For government entities and judicial officers, the opinion offers a roadmap to early dismissal where plaintiffs recycle claims from prior actions, particularly if the defendants are in privity or closely related to earlier parties. For practitioners counseling pro se litigants, the decision underscores the necessity of strategic consolidation of claims in a first action and the importance of clear, fact-specific pleadings.

Complex Concepts Simplified

Res Judicata (Claim Preclusion): A rule that prevents a party from re-suing on the same claim after a final judgment. If you already brought (or could have brought) your claims in a prior suit involving the same dispute against the same parties or their privies, you cannot start over. In the Third Circuit, this can also reach new defendants with a “close or significant relationship” to prior defendants (Gambocz).
Privity / “Close or Significant Relationship”: Privity refers to a legally recognized alignment of interests between parties. The Third Circuit’s “close or significant relationship” idea extends claim preclusion to new defendants who are functionally tied to the earlier defendants such that relitigation would be unfair or duplicative.
Sua Sponte: Latin for “of one’s own accord.” A court acts sua sponte when it raises an issue on its own, without a motion from a party. Here, the District Court raised preclusion sua sponte, which the Third Circuit deemed permissible in these circumstances (ARIZONA v. CALIFORNIA).
Judicial Immunity: Judges are absolutely immune from damages for acts taken in their judicial capacity within their jurisdiction. Even serious errors, bad motives, or overstepping authority do not strip that immunity; it is lost only when a judge acts without any jurisdiction at all (Figueroa).
Rule 8 and Twombly/Iqbal: Federal complaints must be concise and intelligible (Rule 8) and must allege enough concrete facts to make claims plausible, not just possible (Twombly/Iqbal). Labels and conclusions, or a confusing narrative without clear links to legal claims, are insufficient.
Affirm on Any Basis: An appellate court can affirm a correct result even if the lower court relied on different reasons, so long as the record supports the affirmed result (Murray).
Forfeiture on Appeal: If an appellant doesn’t adequately argue a point in the opening brief, the issue is treated as forfeited and will not be considered (In re Wettach).

Conclusion

The Third Circuit’s decision in Ouaziz v. Murphy offers a clear, if non-precedential, reaffirmation of several settled principles: district courts may invoke claim preclusion sua sponte; adding new defendants or repackaging allegations as a fresh conspiracy does not circumvent preclusion when the core dispute is the same; judicial immunity bars suits against judges for judicial acts within jurisdiction; and complaints—particularly repeat complaints—must satisfy Rule 8 and Twombly/Iqbal’s plausibility threshold. The Court’s refusal to reach alternative grounds (like limitations) underscores that where preclusion, immunity, and pleading failures converge, dismissal with prejudice is both appropriate and efficient. For litigants, the message is straightforward: bring a clear, unified, and factually supported case the first time, and do not expect to relitigate the same controversy by changing captions, defendants, or labels.

Note: This disposition is designated “NOT PRECEDENTIAL” and does not constitute binding precedent under Third Circuit I.O.P. 5.7. Its value lies in practical guidance and its synthesis of preclusion, immunity, and pleading doctrines in the recurring context of serial civil-rights litigation arising from state domestic proceedings.