The opinion
UNITED STATES DISTRICT COURT
DISTRICT OF NEW JERSEY
LOUIS ANTHONY MAYE,
Civil Action No. 25-14954 (JXN)(JBC)
Plaintiff,
v.
MEMORANDUM OPINION
AND ORDER
STEPHEN L. PETRILLO, GRACE
SPENCER, LISA M. AUDUBATO,
Defendants.
NEALS, District Judge
Before the Court is pro se Plaintiff Louis Anthony Maye El’s (“Plaintiff”) Complaint (ECF
No. 1) and an application to proceed in forma pauperis (“IFP”) (ECF No. 1-2). Plaintiff's IFP
application establishes Plaintiff's financial eligibility to proceed without prepayment of the filing
fee and is GRANTED. As Plaintiff has been granted IFP status, Plaintiff’s Complaint is subject
to the Court's sua sponte screening. 28 U.S.C. § 1915(e)(2). For the reasons set forth below,
Plaintiff’s Complaint is DISMISSED with prejudice.
I. BACKGROUND1
Plaintiff filed his Complaint on August 26, 2025, naming three judges from the Superior
Court of New Jersey, Essex County: Stephen Petrillo, J.S.C. (“Judge Petrillo”), L. Grace Spencer,
J.S.C. (“Judge Spencer”), and Lisa M. Audubato, J.S.C. (“Judge Audubato”) (collectively
“Defendants”). (See generally Compl., ECF No. 1.) In the “Affidavit of Truth in Facts” attached
1 The Court will accept as true the factual allegations in the Complaint for the purposes of this screening only. The
Court has made no findings as to the veracity of Plaintiff’s allegations. Denton v. Hernandez, 504 U.S. 25, 32 (1992)
(“[T]he § 1915(d) frivolousness determination . . . cannot serve as a factfinding process for the resolution of disputed
facts.”)
to the Complaint, Plaintiff cites several federal and Georgia state statutes in support of his claims,
but the Complaint’s allegations are sparse and difficult to follow. (See id. and Aff. at *2, ECF No.
1-1.) Nonetheless, it appears that Defendants presided over state-court cases in which Plaintiff was
the defendant between August 2023 and September 2024. (Compl. *4.) Plaintiff’s allegations seem
to rest on the belief that Defendants were biased or prejudiced against him during those
proceedings. (Id. at *3, 9.) Plaintiff’s claims are directed at several final determinations made by
Defendants against him in those state-court cases. (Id. at *6.)
II. LEGAL STANDARD
When a plaintiff files a complaint and is granted IFP status, 28 U.S.C. § 1915(e)(2)(B)
requires courts to review the complaint and dismiss claims that are: (1) frivolous or malicious; (2)
fail to state a claim on which relief may be granted; or (3) seek monetary relief against a defendant
who is immune from such relief. Courts, however, must liberally construe pleadings that are filed
pro se. Erickson v. Pardus, 551 U.S. 89, 94 (2007). The legal standard for dismissing a complaint
for failure to state a claim, pursuant to 28 U.S.C. § 1915(e)(2)(B)(ii), is the same as that for
dismissal under Federal Rule of Civil Procedure 12(b)(6). See Schreane v. Seana, 506 F. App'x
120, 122 (3d Cir. 2012). “To survive a motion to dismiss, a complaint must contain sufficient
factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Ashcroft v.
Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. Twombly, 550 U.S. 544, 570
(2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the
court to draw the reasonable inference that the defendant is liable for the misconduct alleged.”
Twombly, 550 U.S. at 556.
III. DISCUSSION
A. Judicial Immunity
“It is a well-settled principle of law that judges are generally ‘immune from a suit for
money damages.’” Figueroa v. Blackburn, 208 F.3d 435, 440 (3d Cir. 2000) (quoting Mireles v.
Waco, 502 U.S. 9, 11 (1991)). “A judge will not be deprived of immunity because the action [they]
took was in error, was done maliciously, or was in excess of [their] authority.” Stump v. Sparkman,
435 U.S. 349, 356 (1978). See also Gallas v. Supreme Court of Pa., 211 F.3d 760, 769 (3d Cir.
2000) (“[I]mmunity will not be lost merely because the judge's action is ‘unfair’ or
controversial.”). As judges of the Superior Court of New Jersey, Defendants “[are] absolutely
immune from liability for [their] judicial acts even if [their] exercise of authority is flawed by the
commission of grave procedural errors.” Id. at 359.
“[Judicial] immunity is overcome in only two sets of circumstances.” Mireles, 502 U.S. at
11. “First, a judge is not immune from liability for nonjudicial actions, i.e., actions not taken in the
judge's judicial capacity.” Id. In determining whether an act qualifies as a “judicial act,” courts
look to “the nature of the act itself, i.e., whether it is a function normally performed by a judge,
and to the expectations of the parties, i.e., whether they dealt with the judge in [their] judicial
capacity.” Stump, 435 U.S. at 362. “Second, a judge is not immune for actions, though judicial in
nature, taken in the complete absence of all jurisdiction.” Mireles, 502 U.S. at 12. Here, Plaintiff's
claims against Defendants are barred under the doctrine of judicial immunity because (i) the
alleged harms appear to stem from Defendants' actions in their judicial capacity, and (ii) Plaintiff
does not allege that Defendants acted in “complete absence of all jurisdiction.” Figueroa, 208 F.3d
at 440. Accordingly, Plaintiff's claims against Defendants are barred in toto on the basis of judicial
immunity.
IV. CONCLUSION
For the foregoing reasons,
IT IS on this 25th day of June 2026,
ORDERED that Plaintiff's IFP application (ECF No. 1-1) is GRANTED, it is further
ORDERED that the Complaint (ECF No. 1) is DISMISSED with prejudice; and it is
further
ORDERED that the Clerk of the Court shall serve a copy of this Memorandum Opinion
and Order upon Plaintiff by regular U.S. mail and shall CLOSE the file.
United States District Judge