Philadelphia court official granted constitutional immunity from inmate's civil rights suit

By Nicholas Malfitano | Jan 13, 2016

U.S. District Court for the Eastern District of Pennsylvania  

PHILADELPHIA – A Philadelphia Municipal Court official has been granted immunity and dismissed from a civil rights suit brought by a city inmate.

Judge Norma L. Shapiro of the U.S. District Court for the Eastern District of Pennsylvania ruled on Monday that Sheila Bedford, an arraignment court magistrate, would be removed from an extensive civil rights violations lawsuit filed by John Hart, an inmate at Curran-Fromhold Correctional Facility.

Hart alleged Bedford assigned him a public defender at his Nov. 17, 2011 bail hearing, after determining he did not qualify for one based on his income. Hart also alleged Bedford appointed that same public defender above Hart’s desire to represent himself, and denied him allocution at the bail hearing.

Therefore, Hart sued Bedford both individually and in her official capacity – in addition to the City of Philadelphia and 22 other defendants related to this litigation. Shapiro’s opinion on behalf of the U.S. District Court for the Eastern District of Pennsylvania is related to Hart’s claims against Bedford only.

Shapiro explained Bedford is immune from litigation, both individually and in her official capacity with the Philadelphia Municipal Court.

“The Philadelphia Municipal Court, Bedford’s employer, is an entity in Pennsylvania’s Unified Judicial System (UJS), a state agency entitled to sovereign immunity under the Eleventh Amendment to the United States Constitution,” Shapiro said.

“Bedford is immune from suit in her individual capacity because ‘judicial officers in the performance of their duties have absolute immunity from suit and will not be liable for their judicial acts,” Shapiro added. “Bedford is also immune from suit in her official capacity because the UJS is not a ‘person’ subject to suit.”

Shapiro explained court magistrates like Bedford are entitled to judicial immunity, since they use discretionary judgment in “presiding at preliminary arraignments, assigning counsel in certain cases, issuing criminal complaints, fixing bail and issuing arrest warrants and search and seizure warrants.”

According to Shapiro, judicial immunity can only be overturned in two sets of circumstances: 1) Actions not taken in the judge’s judicial capacity, and 2) Actions, though judicial in nature, taken in the complete absence of jurisdiction.

“Bedford had jurisdiction over plaintiff’s bail hearing and appointing counsel. Deciding whom to allow to speak are actions typically performed at such hearings. Bedford is immune regardless of whether she erred in such actions,” Shapiro said.

Shapiro reiterated Bedford’s judicial immunity under the U.S. Constitution and officially dismissed her from Hart’s lawsuit.

The plaintiff represented himself in this matter.

The defendant in this instant matter is represented by Martha Gale of the Administrative Office of Pennsylvania Courts, in Philadelphia.

U.S. District Court for the Eastern District of Pennsylvania case 2:13-cv-06661

From the Pennsylvania Record: Reach Courts Reporter Nicholas Malfitano at

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