Case Explained: LIGERI V. PARKER, ET AL.

Court: United States Court of Appeals for the Ninth Circuit Filed: 2026-06-29 Docket: 2:25-cv-00829-KKE The Ninth Circuit affirmed the district court’s judgment dismissing Benjamin Ligeri’s pro se civil action alleging federal and state law claims arising from statements made by defendants in prior litigation. The court applied a de novo standard of review to the dismissal under Federal Rule of Civil Procedure 12(b)(6), holding that the complaint failed to allege sufficient facts to state a plausible claim for relief as required by *Ashcroft v. Iqbal*. Specifically, the panel determined that Ligeri lacked a cognizable legal theory, noting that criminal statutes generally do not imply private rights of action and that Washington law shields attorneys, parties, and witnesses from liability for statements made in the course of judicial proceedings that are pertinent to the litigation. The court further affirmed the district court’s denial of leave to amend, finding such amendment would be futile, and its denial of a motion for reconsideration due to Ligeri’s failure to establish a basis for relief. Arguments not specifically raised in the opening brief were deemed waived. Practically, the judgment is final; Ligeri’s request for costs on appeal is denied, and consideration of the defendants’ request for attorney’s fees is transferred back to the district court. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.