Dennis v. Sparks
| Dennis v. Sparks | |
|---|---|
| Argued October 8, 1980 Decided November 17, 1980 | |
| Full case name | Dennis v. Sparks ET AL., DBA Sidney A. Sparks, Trustee |
| Citations | 449 U.S. 24 (more) 101 S. Ct. 183; 66 L. Ed. 2d 185; 1980 U.S. LEXIS 9 |
| Case history | |
| Prior | Sparks v. Duval County Ranch Co., 604 F.2d 976 (5th Cir. 1979); cert. granted, 445 U.S. 942 (1980). |
| Holding | |
| The action against the private parties accused of conspiring with the judge is not subject to dismissal. Private persons, jointly engaged with state officials in a challenged action, are acting "under color" of law for purposes of 1983 actions. And the judge's immunity from damages liability for an official act that was allegedly the product of a corrupt conspiracy involving bribery of the judge does not change the character of his action or that of his co-conspirators. Historically at common law, judicial immunity does not insulate from damages liability those private persons who corruptly conspire with a judge. Nor has the doctrine of judicial immunity been considered historically as excusing a judge from responding as a witness when his co-conspirators are sued, even though a charge of conspiracy and judicial corruption will be aired and decided. Gravel v. United States distinguished. The potential harm to the public from denying immunity to co-conspirators if the factfinder mistakenly upholds a charge of a corrupt conspiracy is outweighed by the benefits of providing a remedy [449 U.S. 24, 25] against those private persons who participate in subverting the judicial process and in so doing inflict injury on other persons. pp. 27–32. | |
| Court membership | |
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| Case opinion | |
| Majority | White, joined by unanimous |
Dennis v. Sparks, 449 U.S. 24 (1980), was a case in which the Supreme Court of the United States held that individuals who bribed a judge for an injunction were not protected by judicial immunity and therefore could be held liable for the damages resulting from the injunction.