Opinion

LOUIS ANTHONY MAYE v. STEPHEN L. PETRILLO, GRACE SPENCER, LISA M. AUDUBATO

Court
District Court, D. New Jersey
Filed
Jun 25, 2026
Cited by
0 cases
Authority
More cited than 41.3%

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

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.

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