Tenth Circuit Confirms: § 1983 Injunctive/Declaratory Relief Requires Official-Capacity Suits; New Mexico Civil Rights Act Does Not Waive Eleventh Amendment Immunity in Federal Court

Tenth Circuit Confirms: § 1983 Injunctive/Declaratory Relief Requires Official-Capacity Suits; New Mexico Civil Rights Act Does Not Waive Eleventh Amendment Immunity in Federal Court

Introduction

In Springer v. Seventh Judicial District Court, No. 24-2174 (10th Cir. Nov. 7, 2025), a panel of the United States Court of Appeals for the Tenth Circuit (Judges Hartz, Moritz, and Eid) affirmed dismissal of a civil-rights suit brought by James Springer, a self-described independent investigative journalist. Springer alleged that New Mexico Seventh Judicial District officials—including two district judges, the court’s executive officer, and a clerk—restricted his access to courthouses and public records, retaliated against him for protected speech, and sought removal of one of his YouTube videos.

The case presented two threshold questions, not the merits of Springer's First and Fourteenth Amendment theories:

  • Whether a plaintiff may obtain injunctive or declaratory relief under 42 U.S.C. § 1983 against state officials sued in their individual (personal) capacities; and
  • Whether the Eleventh Amendment permits a federal-court suit under the New Mexico Civil Rights Act (NMCRA) against a New Mexico state court and whether state law waives that immunity.

The Tenth Circuit answered both questions against the plaintiff: § 1983 does not authorize injunctive or declaratory relief against defendants in their individual capacities, and the Eleventh Amendment bars the NMCRA claim in federal court because the statute does not unequivocally consent to federal jurisdiction.

Summary of the Opinion

Affirming the district court, the Tenth Circuit held:

  • Springer sued the individual defendants only in their personal capacities but sought purely injunctive and declaratory relief. Under binding circuit authority, § 1983 does not permit injunctive or declaratory relief against officials in their individual capacities. See Chilcoat v. San Juan County, 41 F.4th 1196, 1214 (10th Cir. 2022). The court therefore affirmed dismissal of the First Amendment viewpoint-discrimination and retaliation counts and the Fourteenth Amendment due-process count as to the individuals without reaching other defenses.
  • The claim against the Seventh Judicial District itself is barred by Eleventh Amendment sovereign immunity because New Mexico district courts are arms of the state. See Collins v. Daniels, 916 F.3d 1302, 1316 (10th Cir. 2019). Supplemental jurisdiction under 28 U.S.C. § 1367 does not abrogate Eleventh Amendment immunity. See Raygor v. Regents of Univ. of Minn., 534 U.S. 533, 541–42 (2002).
  • New Mexico has not unequivocally waived its Eleventh Amendment immunity in federal court for NMCRA claims. The NMCRA’s general no-immunity clause (N.M. Stat. Ann. § 41-4A-9) does not specifically consent to suits in federal court, as required by Atascadero State Hospital v. Scanlon, 473 U.S. 234, 241 (1985) and Sossamon v. Texas, 563 U.S. 277, 284–85 (2011).
  • While federal courts often decline supplemental state-law claims after dismissing all federal claims pretrial, it was proper here to dismiss the NMCRA claim on Eleventh Amendment grounds because that disposition rests on federal law and does not implicate comity concerns. The court emphasized that this dismissal does not foreclose bringing the NMCRA claim in state court.

The decision is designated as an “Order and Judgment,” nonprecedential but citable for its persuasive value under Fed. R. App. P. 32.1 and 10th Cir. R. 32.1.

Factual and Procedural Background

According to the well-pleaded allegations accepted as true on a motion to dismiss, Chief Judge Mercedes Murphy issued an Administrative Order barring Springer from the Torrance County courthouse unless escorted and present for specific court business, citing staff harassment. After further reports of disruption, an amended order extended the restrictions to other courthouses in the Seventh Judicial District. Springer alleged that:

  • Chief Judge Murphy and Judge Shannon Murdock-Poff prevented his attendance at public hearings in person and by video;
  • Clerk Susan Rossignol denied him access to public records and required police presence during his entries;
  • Rossignol, at Chief Judge Murphy’s direction, falsely reported him as an armed threat; and
  • All defendants conspired to get YouTube to remove one of his videos.

Springer’s second amended complaint asserted four counts: (1) First Amendment viewpoint discrimination under § 1983 (against the two judges); (2) First Amendment retaliation under § 1983 (against all defendants); (3) Fourteenth Amendment due process under § 1983 (against the individuals); and (4) violations of the New Mexico Bill of Rights under the NMCRA (against the Seventh Judicial District). He sought declaratory and injunctive relief from the individuals, and damages from the Seventh Judicial District.

The district court dismissed but granted leave to amend the federal claims to name at least Chief Judge Murphy in her official capacity. Springer declined to amend, obtained a final judgment, and appealed. The Tenth Circuit exercised appellate jurisdiction under 28 U.S.C. § 1291 and affirmed.

Precedents Cited and How They Shaped the Decision

  • Chilcoat v. San Juan County, 41 F.4th 1196, 1214 (10th Cir. 2022): Central to the disposition of the federal claims against the individual defendants. Chilcoat holds that § 1983 does not authorize injunctive or declaratory relief against officials in their individual capacities. Relief of that type must be sought via official-capacity claims (often under the Ex parte Young framework). The court applied Chilcoat to conclude that Springer’s personal-capacity claims seeking only prospective relief fail as a matter of law.
  • Commonwealth Property Advocates, LLC v. MERS, 680 F.3d 1194, 1201–02 (10th Cir. 2011): Provided the Rule 12(b)(6) standard and allowed consideration of exhibits attached to the complaint when assessing sufficiency.
  • Pettigrew v. Oklahoma ex rel. Dep’t of Public Safety, 722 F.3d 1209, 1212 (10th Cir. 2013), and Pennhurst State School & Hospital v. Halderman, 465 U.S. 89, 100 (1984): Framed Eleventh Amendment immunity: it generally bars private suits in federal court against nonconsenting states regardless of relief sought, and extends to “arms of the state.”
  • Ambus v. Granite Board of Education, 995 F.2d 992, 994 (10th Cir. 1993) (en banc), and Collins v. Daniels, 916 F.3d 1302, 1316 (10th Cir. 2019): Established that New Mexico district courts are “arms of the state” and thus enjoy Eleventh Amendment immunity.
  • Raygor v. Regents of University of Minnesota, 534 U.S. 533, 541–42 (2002): Confirmed that 28 U.S.C. § 1367 does not extend supplemental jurisdiction to claims against nonconsenting state defendants. Plaintiffs cannot use § 1367 to haul a state (or arm of the state) into federal court.
  • Sossamon v. Texas, 563 U.S. 277, 284–85 (2011); Atascadero State Hospital v. Scanlon, 473 U.S. 234, 241 (1985); Griess v. Colorado, 841 F.2d 1042, 1044 (10th Cir. 1988): These decisions articulate the stringent, “unequivocally expressed” standard for state waiver of Eleventh Amendment immunity in federal court and reject general waivers not expressly consenting to federal jurisdiction. The panel applied this framework to hold that New Mexico’s NMCRA non-immunity clause does not clearly consent to federal suits.
  • City of Roswell v. Sanchez-Gagne, No. S-1-SC-40437, 2025 WL 1821706, at *3 (N.M. July 2, 2025): Cited for the NMCRA’s purpose—creating a private right of action to enforce New Mexico Bill of Rights guarantees—but not as a basis for federal jurisdiction.
  • Bauchman v. West High School, 132 F.3d 542, 549–50 (10th Cir. 1997), and 28 U.S.C. § 1367(c)(3): Provided the backdrop for why federal courts ordinarily decline supplemental state-law claims once federal claims are dismissed pretrial. The panel explained that it was nevertheless appropriate here to resolve the NMCRA claim on Eleventh Amendment grounds, a threshold federal-law bar.

Legal Reasoning

1) Federal claims against the individuals: capacity matters

Springer’s complaint expressly sought only declaratory and injunctive relief against the individual defendants, and did so solely in their personal capacities. Under established Tenth Circuit law, § 1983 does not support such relief in personal-capacity suits. The proper vehicle for prospective relief against state actors is an official-capacity claim, which is in substance a claim against the office. Because the pleading elected the wrong capacity for the type of relief sought, dismissal was required.

Importantly, the district court offered leave to amend to name at least Chief Judge Murphy in her official capacity, signaling the correct procedural path (and the availability of the Ex parte Young route for prospective relief from alleged ongoing federal-law violations). Springer declined to amend, chose to stand on his defective complaint, and obtained a final judgment for appeal. The Tenth Circuit therefore did not reach other potential defenses (such as judicial immunity limitations on injunctive relief against judges, or the merits).

2) State-law NMCRA claim against the Seventh Judicial District: Eleventh Amendment bar

The court next treated the NMCRA claim against the Seventh Judicial District itself. New Mexico’s district courts are arms of the state and thus cloaked with Eleventh Amendment immunity. That immunity:

  • Is not displaced by supplemental jurisdiction under 28 U.S.C. § 1367(a) (Raygor); and
  • Is not waived by the NMCRA’s general statement that “the state shall not have sovereign immunity” for NMCRA claims (N.M. Stat. Ann. § 41-4A-9) because the statute does not specify consent to suit in federal court (Sossamon; Atascadero; Griess).

Because the NMCRA contains no express, unequivocal consent to federal jurisdiction, the claim could not proceed in federal court against the state court. The panel emphasized that this dismissal does not preclude pursuit of the NMCRA claim in New Mexico state court.

3) Supplemental jurisdiction and prudence

The Tenth Circuit acknowledged that federal courts ordinarily decline supplemental state-law claims once all federal claims have been dismissed before trial, due to comity and federalism concerns. But here the district court dismissed the NMCRA claim on the federal-law ground of Eleventh Amendment immunity, a threshold jurisdictional issue. That approach was “eminently proper,” and the panel approved it.

Impact and Implications

A. Practical guidance for civil-rights litigants

  • Choose the correct capacity for the relief sought. If a plaintiff seeks prospective relief (injunction or declaration) to halt an ongoing violation of federal law by state officials, the suit must be brought against those officials in their official capacities (typically under Ex parte Young). Personal-capacity suits are the avenue for damages, not for prospective relief.
  • Expect Eleventh Amendment barriers in federal court for state-law claims against the state or its arms. Plaintiffs cannot use § 1367 supplemental jurisdiction to anchor state-law claims against nonconsenting state entities in federal court, nor rely on general state-law no-immunity clauses that do not expressly consent to federal jurisdiction.
  • Forum selection matters. In New Mexico, NMCRA claims against the state or its arms must ordinarily be filed in state court. Pennhurst further bars federal courts from ordering state officials to comply with state law; thus, even official-capacity suits in federal court generally cannot compel state-law compliance.
  • Be mindful of additional constraints for judicial officers. Even when suing a judge in an official capacity for prospective relief, 42 U.S.C. § 1983—amended in 1996—limits injunctive relief against judicial officers for acts taken in a judicial capacity, unless a declaratory decree has been violated or declaratory relief is unavailable. Though the panel did not reach this issue, it is a notable constraint in courthouse-access cases.

B. For state and local governments

  • State courts remain protected by Eleventh Amendment immunity in federal court. This decision reinforces that arms of the state—like New Mexico’s district courts—are generally immune from suit in federal court absent clear congressional abrogation or an unequivocal state waiver specifying federal court.
  • Policy litigation will migrate to state courts where statutes like the NMCRA remove state-law sovereign immunity. Agencies should expect state-forum adjudication of NMCRA claims and prepare appropriate litigation and settlement strategies for that forum.

C. Doctrinal clarity within the Tenth Circuit

  • Reaffirmation of Chilcoat. The panel provides another clear application of the rule that § 1983 injunctive/declaratory relief is not available against individual-capacity defendants, a frequent pleading misstep in civil-rights litigation.
  • First circuit-level application to NMCRA waiver. While grounded in established Supreme Court law on waiver, the opinion squarely addresses New Mexico’s 2021 NMCRA and confirms it does not waive Eleventh Amendment immunity for federal-court suits. Expect district courts within the Tenth Circuit to treat this as persuasive authority.

Complex Concepts, Simplified

  • Individual vs. official capacity: Suing a state official in their individual capacity seeks to impose personal liability (typically damages). Suing in official capacity is effectively suing the office; it allows for prospective injunctive or declaratory relief to halt an ongoing violation of federal law.
  • Injunctive vs. declaratory relief: Injunctions order someone to do or stop doing something. Declaratory judgments state what the law is or the parties’ rights. Under § 1983, these forms of relief are pursued via official-capacity claims against state officers, not personal-capacity claims.
  • Eleventh Amendment immunity: The Eleventh Amendment protects states and their “arms” (state agencies, courts, some boards) from being sued in federal court by private parties, unless (a) Congress validly abrogates that immunity using unmistakably clear language under an appropriate constitutional power, or (b) the state unequivocally consents to suit in federal court.
  • Abrogation vs. waiver: Abrogation is federal override (by Congress) of state immunity; waiver is the state’s consent. Both require clear statements. General state-law “no immunity” provisions are not enough to show consent to federal jurisdiction; they must specifically mention suits in federal court.
  • Ex parte Young (1908): A critical exception allowing suits in federal court against state officials (in their official capacities) for prospective relief to end ongoing violations of federal law. It does not permit damages and does not apply to state-law claims (Pennhurst).
  • Pennhurst rule: Federal courts cannot order state officials to comply with state law in official-capacity suits; such claims belong in state court.
  • Supplemental jurisdiction (§ 1367): Allows federal courts to hear related state-law claims, but it does not extend federal jurisdiction to claims against nonconsenting states (Raygor). Nor does it override the Eleventh Amendment.

What the Court Did Not Decide

  • The merits of Springer’s First Amendment viewpoint-discrimination and retaliation claims, or his due-process claim.
  • Whether any administrative or courtroom access restrictions imposed by the judges were constitutionally permissible.
  • Other potential defenses, such as judicial immunity limitations on injunctive relief, qualified immunity (irrelevant to prospective relief but relevant to damages), or the state-action implications of coordinating with a private platform (YouTube).

Key Takeaways

  • To obtain prospective relief against state officials under § 1983, plead official-capacity claims; individual-capacity claims cannot yield injunctive or declaratory relief in the Tenth Circuit.
  • New Mexico district courts are arms of the state and immune from federal suits; the NMCRA does not waive Eleventh Amendment immunity in federal court because it does not expressly consent to federal jurisdiction.
  • State-law constitutional claims under the NMCRA should be brought in New Mexico state courts; federal courts cannot entertain them against the state or its arms absent an unequivocal federal-forum waiver.
  • Ex parte Young remains the best route in federal court for prospective relief against ongoing federal-law violations by state officials.
  • This nonprecedential decision is persuasive and will likely guide district courts within the Tenth Circuit on NMCRA-related Eleventh Amendment questions.

Conclusion

Springer v. Seventh Judicial District Court reinforces two foundational procedural rules in civil-rights litigation within the Tenth Circuit: (1) injunctive and declaratory relief under § 1983 must be sought via official-capacity claims, not individual-capacity suits; and (2) the Eleventh Amendment bars federal-court NMCRA claims against New Mexico and its arms because the NMCRA contains no unequivocal consent to federal jurisdiction. While the court did not reach the substance of Springer’s constitutional allegations, its decision sharply delineates the permissible pathways to relief and underscores the importance of forum selection and capacity pleading. Litigants seeking to challenge state action should calibrate their pleadings accordingly—pursuing federal constitutional relief against state officials in their official capacities in federal court, and state constitutional claims under the NMCRA in New Mexico state courts.

Case Details

Year: 2025
Court: Court of Appeals for the Tenth Circuit

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