Case Explained: CYRUS SANAI V. ALEX KOZINSKI, ET AL

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-18 Docket: 4:19-cv-08162-YGR The Ninth Circuit affirmed the district court’s dismissal of Cyrus Sanai’s civil rights claims against federal judges, court staff, and the Judicial Councils of the Ninth and California Circuits. The court held that the district court correctly applied sovereign immunity to dismiss claims against the Judicial Councils in their official capacities, reasoning that the Administrative Procedure Act excludes “courts of the United States” from its waiver of immunity and that the Larson-Dugan exception for ultra vires actions did not apply because the bodies acted within their statutory powers. Furthermore, the court affirmed the dismissal of claims against individual judges and staff based on absolute judicial immunity and quasi-judicial immunity, determining that sanctioning an attorney is a judicial act rather than an administrative one, and that clerks’ actions integral to judicial functions are similarly immune. The appellate court also found no abuse of discretion in denying Sanai’s motions for recusal under 28 U.S.C. § 455(a), noting a lack of evidence that the judges’ impartiality might reasonably be questioned, and affirmed the denial of leave to amend and post-judgment motions as futile given the applicable immunities. Consequently, Sanai’s appeal is dismissed with no relief granted, and his pending miscellaneous motions are denied as moot or without merit. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.