Tenth Circuit Clarifies That Ex Parte Young Normally Does Not Permit Injunctions Against State Judges or Clerks; Sovereign and Quasi‑Judicial Immunity Defeat § 1983 Challenge to State‑Court Filing Restrictions

Case: Jackson v. Mason — United States Court of Appeals for the Tenth Circuit (No. 24-3131, Sept. 3, 2025)

Panel: Chief Judge Holmes, Judges Tymkovich and Moritz

Disposition: Affirmed (order and judgment; nonprecedential but citable for persuasive value under Fed. R. App. P. 32.1 and 10th Cir. R. 32.1)

Introduction

In Jackson v. Mason, the Tenth Circuit affirmed dismissal of a pro se litigant’s § 1983 suit challenging state‑court filing restrictions imposed and enforced by a state judge and her courtroom clerk in Johnson County, Kansas. The plaintiff, Kris Chapter Jackson, alleged that the restrictions were discriminatory and violated her right of access to the courts. She sued the presiding state judge, the judge’s clerk/administrative assistant, the Johnson County District Court, and unnamed “Doe” defendants.

The appeal required the court to decide whether sovereign immunity and quasi‑judicial immunity bar such claims, whether the district court was obliged to allow discovery before ruling on immunity, whether the court improperly applied a heightened pleading standard to a pro se litigant, and whether the Ex Parte Young doctrine could salvage requests for prospective injunctive relief against a state judge and clerk. The Tenth Circuit answered each question in favor of the defendants, notably emphasizing that Ex Parte Young “does not normally permit federal courts to issue injunctions against state‑court judges or clerks,” echoing the Supreme Court’s 2021 guidance in Whole Woman’s Health v. Jackson, 595 U.S. 30.

Summary of the Judgment

Sovereign immunity (Eleventh Amendment): The official‑capacity claims against the state judge and the court, as well as the official‑capacity claims against the clerk, were barred. The Johnson County District Court and its judicial officers, when sued in their official capacities, are arms of the State of Kansas for Eleventh Amendment purposes.
Quasi‑judicial immunity: The individual‑capacity claims against the clerk failed because the clerk’s actions (refusing to docket or process filings under the judge’s restrictions) were integral to the judicial process and undertaken at the direction of the judge.
Ex Parte Young exception rejected: The court held that Ex Parte Young’s narrow avenue for prospective injunctive relief against state officials did not apply to suits seeking injunctions against state‑court judges or their clerks with respect to case‑management functions.
Procedural rulings affirmed: The district court properly treated sovereign immunity as a Rule 12(b)(1) jurisdictional issue, could resolve the case at the pleading stage without discovery, and appropriately admonished page‑limit violations while still fully considering the pro se filings.
Issues abandoned on appeal: The plaintiff did not pursue the state‑law negligence claim or the Doe‑defendant dismissals on appeal; those rulings were affirmed.

Analysis

Precedents Cited and Their Influence

Ashcroft v. Iqbal, 556 U.S. 662 (2009) — The court reiterated the plausibility standard governing Rule 12(b)(6): a complaint must contain sufficient factual matter, accepted as true, to state a claim that is plausible on its face. This standard justified resolving the defense motions on the pleadings without discovery.
Waller v. City & County of Denver, 932 F.3d 1277 (10th Cir. 2019) — Cited for de novo review of dismissals and the requirement to accept well‑pleaded allegations as true and draw reasonable inferences for the plaintiff.
Hennessey v. University of Kansas Hospital Authority, 53 F.4th 516 (10th Cir. 2022) — Confirmed de novo review of Rule 12(b)(1) dismissals for lack of subject‑matter jurisdiction, relevant to the sovereign immunity analysis.
Normandy Apartments, Ltd. v. HUD, 554 F.3d 1290 (10th Cir. 2009) and Arbaugh v. Y&H Corp., 546 U.S. 500 (2006) — Emphasized that sovereign immunity implicates subject‑matter jurisdiction and that courts have an independent obligation to assess jurisdiction even absent party invocation. This supported the district court’s conversion of part of the 12(b)(6) motion into a 12(b)(1) posture without separate notice.
Green v. Mansour, 474 U.S. 64 (1985) and Ex Parte Young, 209 U.S. 123 (1908) — Framed the limited exception to sovereign immunity for prospective injunctive relief to halt ongoing violations of federal law.
Whole Woman’s Health v. Jackson, 595 U.S. 30 (2021) — Crucial authority: the Supreme Court stated that Ex Parte Young “does not normally permit federal courts to issue injunctions against state‑court judges or clerks.” The Tenth Circuit relied on this to reject plaintiff’s request for injunctive relief aimed at a state judge and clerk’s case‑management decisions (filing restrictions and docketing).
Callahan v. Unified Government of Wyandotte County, 806 F.3d 1022 (10th Cir. 2015) — Clarified the qualified immunity framework; the panel explained qualified immunity was irrelevant because defendants did not invoke it and the district court did not rely on that defense.
Garrett v. Selby Connor Maddux & Janer, 425 F.3d 836 (10th Cir. 2005) — Confirmed that pro se litigants must follow procedural rules, undercutting the claim that the district court unfairly held the plaintiff to a heightened pleading standard.
Timmerman v. U.S. Bank, N.A., 483 F.3d 1106 (10th Cir. 2007) — Approved district courts’ enforcement of page limits and related case‑management discretion.
Murrell v. Shalala, 43 F.3d 1388 (10th Cir. 1994) — Addressed issue preservation and abandonment on appeal; the panel used it to treat the negligence and Doe‑defendant issues as forfeited.

Legal Reasoning

1) Eleventh Amendment Sovereign Immunity and Official‑Capacity Claims

The court affirmed dismissal of official‑capacity claims against the state judge, the state court, and the clerk. Suits against state officials in their official capacity are, for immunity purposes, suits against the State itself. State courts are arms of the State. Absent waiver or valid congressional abrogation—neither present here—Eleventh Amendment immunity deprives federal courts of subject‑matter jurisdiction over such claims. The district court was both permitted and obliged to consider sovereign immunity under Rule 12(b)(1), even if defendants framed their motion under Rule 12(b)(6).

2) Quasi‑Judicial Immunity for Court Personnel

For individual‑capacity claims against the clerk, the court recognized quasi‑judicial immunity. Clerks and other court personnel are absolutely immune from suit when performing duties intimately associated with the judicial process, especially when acting at the direction of a judge. Here, the complained‑of actions—refusing to docket or process filings under the judge’s restrictions and communicating those restrictions—were integral to the judicial function and thus immune from damages liability.

3) Ex Parte Young’s Limited Exception Does Not Apply to Enjoin State Judges or Clerks

The plaintiff sought to bypass sovereign immunity by invoking Ex Parte Young, arguing that she sought prospective injunctive relief for an ongoing violation. The panel rejected this for two reasons:

The Supreme Court has clarified that Ex Parte Young “does not normally permit federal courts to issue injunctions against state‑court judges or clerks.” Whole Woman’s Health v. Jackson, 595 U.S. at 39. Enjoining a judge’s or clerk’s case‑management decisions would trench on state judicial processes and federalism.
The very origin of Ex Parte Young cautions that such injunctions against judges or clerks “would be a violation of the whole scheme of our government.” Ex Parte Young, 209 U.S. at 180 (quoted by the panel).

Accordingly, the injunctive‑relief component of the § 1983 claims failed at the threshold. The panel did not need to reach other potential barriers to injunctive relief against judicial officers (such as the statutory limits added to § 1983 in 1996), because Whole Woman’s Health supplied a sufficient ground.

4) No Error in Dismissing on the Pleadings Without Discovery

The district court accepted the plaintiff’s well‑pleaded allegations as true and, applying Iqbal, determined that even if the alleged facts were accurate, sovereign immunity and quasi‑judicial immunity barred relief. Because immunity defenses are threshold questions often resolved at the pleading stage, the court did not err by dismissing without discovery, a trial, or an evidentiary hearing.

5) Pro Se Status Does Not Excuse Noncompliance with Procedural Rules

The plaintiff argued that the district court admonished her as a “vexatious litigant” and imposed a heightened pleading standard. The Tenth Circuit disagreed. The court merely enforced local page‑limit rules and, despite that violation, fully considered the response. Pro se litigants must comply with procedural rules, and the district court’s warning and handling of the filings fell within appropriate case‑management discretion.

6) Qualified Immunity: Not in Play

The plaintiff repeatedly argued that the district court should have analyzed whether she pleaded a violation of a “clearly established” right—a qualified‑immunity inquiry. The panel explained that this argument missed the mark: defendants did not assert qualified immunity, and the case was resolved on sovereign immunity and quasi‑judicial immunity grounds. There was therefore no need to reach qualified‑immunity questions.

7) Abandonment of Negligence and Doe‑Defendant Issues

The panel noted that the plaintiff did not substantively challenge the district court’s dismissal of the state‑law negligence claim or the dismissal of Doe defendants (both for immunity and for failure to identify and serve them). Those rulings were accordingly affirmed as abandoned.

Impact and Significance

Clarified limits on federal injunctive relief against state judicial actors: The decision reinforces, within the Tenth Circuit, the Supreme Court’s instruction that Ex Parte Young does not ordinarily support injunctions aimed at state‑court judges or clerks over case‑management actions, including filing restrictions. Litigants aggrieved by such orders must generally pursue remedies within the state judicial system (e.g., appeal, mandamus, supervisory review), not federal § 1983 suits for injunctive relief against the judge or clerk.
Strong protection for court personnel executing judicial directives: The ruling underscores the breadth of quasi‑judicial immunity for clerks acting at a judge’s direction or performing judicially linked functions—particularly concerning docket control and enforcement of filing restrictions.
Procedural clarity on immunity at the pleading stage: Sovereign immunity is jurisdictional and may be resolved on a Rule 12(b)(1) basis, even if the motion is framed otherwise. Courts may dismiss without discovery when immunities clearly bar suit on the face of the complaint.
Pro se litigants remain bound by procedural rules: The case reaffirms that while courts construe pro se filings liberally, they do not relax page limits or pleading standards, and litigants cannot avoid dismissal by insisting on discovery prior to resolution of immunity defenses.
Practical guidance for future plaintiffs: To challenge allegedly unconstitutional filing restrictions, the proper avenue is typically state appellate or supervisory review. Naming state judges or clerks as § 1983 defendants for damages or injunctive relief is likely futile given sovereign, judicial, and quasi‑judicial immunities and the Ex Parte Young limitation highlighted here.

Complex Concepts Simplified

Eleventh Amendment sovereign immunity: The Constitution generally bars lawsuits in federal court against states and their arms (including state courts) unless the state consents or Congress clearly authorizes suit. Suing a state officer in his or her official capacity is treated as suing the state itself.
Ex Parte Young exception: A narrow rule allowing suits for prospective (forward‑looking) injunctions against state officers who are enforcing an unconstitutional law. It normally does not allow injunctions against state judges or clerks about how they run their courtrooms or dockets.
Quasi‑judicial immunity: Absolute immunity for court staff (like clerks) when they carry out tasks intimately tied to the judicial process, especially when acting under a judge’s orders. It protects them from damages suits.
Qualified immunity: A defense for government officials sued in their individual capacities, shielding them unless they violated clearly established law. It was not invoked here and was not the basis for dismissal.
Rule 12(b)(1) vs. Rule 12(b)(6): Rule 12(b)(1) concerns the court’s power to hear the case at all (subject‑matter jurisdiction), implicated by sovereign immunity. Rule 12(b)(6) asks whether the complaint states a claim that is plausible. Courts can address jurisdiction first and must dismiss if they lack it.
Pro se litigation: Courts read pro se pleadings liberally but still require compliance with procedural rules like page limits and deadlines. Liberal construction does not mean a lower pleading standard.
Prospective injunctive relief: A court order that tells a defendant to stop or change behavior going forward. In federal court, such relief cannot usually be directed at state judges or clerks for their adjudicatory or administrative functions.

Conclusion

Jackson v. Mason is a thorough reaffirmation of foundational immunity doctrines as they apply to § 1983 challenges against state judicial actors. The Tenth Circuit held that:

Official‑capacity claims against a state judge, court, and clerk are barred by Eleventh Amendment sovereign immunity;
Individual‑capacity claims against a clerk for enforcing a judge’s filing restrictions are barred by quasi‑judicial immunity; and
The Ex Parte Young exception does not ordinarily permit federal courts to issue injunctions against state‑court judges or clerks regarding case‑management functions.

The opinion also clarifies procedural points: sovereign immunity is jurisdictional and may be resolved without discovery; pro se status does not excuse noncompliance with procedural rules; and issues not properly briefed on appeal are deemed abandoned. While designated nonprecedential, the decision carries persuasive force and offers clear guidance to litigants and courts: constitutional objections to state‑court filing restrictions belong in state appellate channels, not in federal § 1983 suits against the judge or clerk.

Note on Precedential Status

The panel’s order is not binding precedent except under law‑of‑the‑case, res judicata, and collateral estoppel, but it may be cited for persuasive value under applicable rules. Its reasoning, grounded in Whole Woman’s Health v. Jackson and long‑standing immunity doctrines, is likely to influence district courts within the circuit confronting similar challenges to state‑court case‑management decisions.