Case Explained: Non-Argument Calendar DALTON D. BANKS v. DONNA K. LAMONS, et al TAMMY BROWN Honorable, Judge SHERIFF’S DEPARTMENT OF CULLMAN COUNTY ALABAMA

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-08-06 Docket: 6:25-cv-00132-ACA The eleventh-circuit affirmed the district court’s dismissal of Dalton Banks’s § 1983 complaint against Alabama Probate Court Judge Tammy Brown and the Cullman County Sheriff’s Department. The court held that judicial immunity absolutely bars claims against a judge for acts taken in her judicial capacity unless she acted in the “clear absence of all jurisdiction.” Applying the standard from *Sibley v. Lando*, the court determined that issuing an involuntary commitment order is a normal judicial function, occurred in open court regarding a pending case, and thus qualified as a judicial activity protected by immunity. The court rejected Banks’s argument that the judge lacked jurisdiction because the order allegedly violated Alabama law or was void ab initio, clarifying that judicial immunity applies even when a judge acts in error, maliciously, or in excess of jurisdiction, provided she possessed subject-matter jurisdiction over the commitment proceeding. Additionally, the court noted that claims against the Sheriff’s Department were properly dismissed because it is not a legal entity subject to suit under Alabama law, and the district court correctly denied leave to amend the complaint as any amendment would be futile due to sovereign immunity and res judicata. The practical consequence is that the dismissal of the complaint stands, ending the federal civil rights action against the judge and the department. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.