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Civil Rights Claims and Quasi-Judicial Immunity; Melton v. Indiana Athletic Trainers Board

Molly Melton is an athletic trainer licensed by the Athletic Trainers Certification Board. The members of the Board are appointed by the governor and can impose disciplinary sanctions.

While working as an athletic trainer at a School, Melton, then twenty-three years old, began a sexual relationship with an eighteen-year-old male athlete (C.J.). C.J.’s parents discovered the relationship and filed a complaint with the school. Melton was fired and let her license lapse.

After Melton’s license lapsed, the State filed an administrative complaint against her with the Board. A hearing was held, at which Melton appeared by counsel. But the Board found this appearance insufficient and defaulted Melton, after which it
suspended Melton’s license for at least seven years.

Melton filed a complaint alleging that the Board, the Indiana Professional Licensing Agency (IPLA), and the Board’s members violated her constitutional rights. The Board was ordered to vacate the suspension and actually hold a hearing. Melton’s status was changed from “suspended” to “expired,” and the Board held a hearing.

At the hearing, Melton admitted her relationship with C.J., and admitted that it was a mistake. She argued that the three years she had not been able to practice as a trainer was more than enough punishment and introduced opinions from two psychologists opining that she did not pose an unreasonable risk of harm. But the State introduced evidence of arguable improprieties that Melton had previously committed. The Board again found that Melton’s conduct was improper and suspended her for at least three years.

Melton then filed in the trial court (1) a petition seeking judicial review of this administrative decision and (2) a complaint alleging civil rights violations under 42 USC § 1983. The two forms of relief were treated separately.

In the judicial review proceeding, Melton admitted that she was not seeking relief against the Board Members and asked for immediate reinstatement. The Board asked the trial court to affirm its decision. The trial court found that the Board’s decision was arbitrary and capricious, ordered that Melton’s license be reinstated, and awarded attorney’s fees.

Meanwhile, the defendants moved for summary judgment in the 1983 action. They argued that they were not “persons” under the statute, that they were immune, and that the claims against the Board Members failed as a matter of law. At a hearing, the Board argued that the judicial review resolved the claims against it, and that the only claims remaining were against the Board Members. The trial court granted summary judgment, finding that the Board Members were immune. Melton appealed.

On appeal, the Court agreed that both the IPLA and the Board are state agencies, so they are not a “person” under § 1983.

Therefore, the trial court properly granted summary judgment for these entities on the 1983 claims.
It is also generally true that state officials acting in their official capacity are also not “persons” for the purposes of § 1983. But they can be “persons” under this statute for the purposes of injunctive relief. And officers sued in their official capacity cannot claim immunity defenses. Thus, Melton’s claims for injunctive relief could not be dismissed based on immunity (as the trial court did).

But the Court held that the trial court properly granted summary judgment to Melton on these claims anyway because her request for injunctive relief was directed to the Board, not the Board Members. Thus, the only question was whether the Board
Members could be sued in their individual capacities.

The Board Members argued that they were entitled to absolute quasi-judicial immunity.

Quasi-judicial immunity applies to officers “who perform functions closely associated with the judicial process.”

In determining whether a person is entitled to the benefit of absolute immunity, we use the functional approach established by the United States Supreme Court and look to the nature of the function performed rather than the identity of the person who performed it. The touchstone of the functional approach is “performance of the function of resolving disputes between parties, or of authoritatively adjudicating private rights.” Therefore, absolute immunity is available to members of a quasi-judicial adjudicatory body when they perform duties functionally comparable to those of judicial officers.

The United States Supreme Court previously found that administrative agencies which include the following safeguards perform a quasi-judicial function: the need to assure that the person can perform their functions without harassment or intimidation; insulation from political influence; the importance of precedent; the adversarial nature of the process; and the correctability of error on appeal. The Court found that the Board met this test because it had a number of these procedural safeguards. Thus, the trial court properly found that the Board Members were absolutely immune from suit.

The opinion spends a considerable amount of time dealing with the Board’s cross-appeal from the judicial review, but the issues it dealt with are not notable. In short, it found that the Board did not violate Melton’s rights, that it acted within its statutory authority, and that its decision was not arbitrary and capricious. And the Court’s discussion expressed a distinct lack of sympathy for a licensed trainer who claimed she was too “young” and “naïve” to avoid a sexual relationship with a high school student.

Melton’s claims were dismissed, and the suspension of her license was affirmed.

Lessons:

1. Officials in administrative agencies that perform quasi-judicial functions are protected by absolute immunity from Section 1983 claims.
2. There is an Athletic Trainers Certification Board and it is serious about regulating sexual misconduct by athletic trainers.