Case Explained: Non-Argument Calendar JAMES THOMAS CARLAN v. C. ASHLEY ROYAL

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-06-05 Docket: 5:25-cv-00397-MTT The eleventh-circuit affirmed the district court’s order dismissing James Carlan’s in forma pauperis complaint as frivolous. The court applied a de novo review standard for whether a complaint lacks arguable merit under 28 U.S.C. § 1915(e)(2)(B)(i), noting that while pro se pleadings are liberally construed, issues not properly briefed on appeal are deemed abandoned. Carlan failed to challenge the district court’s specific ground for dismissal—that his complaint was frivolous—and instead argued only that Judge Royal unconstitutionally dismissed his prior actions. Regarding the merits of the constitutional claims Carlan attempted to raise, the court held that his First Amendment claim against Judge Ashford was meritless because Judge Ashford was not named as a defendant in the complaint. Furthermore, the court ruled that Carlan’s Seventh Amendment claim regarding the right to a jury trial was meritless because resolving a case on matters of law before trial does not violate the Seventh Amendment. Additionally, the court found that Judge Royal was protected by absolute judicial immunity for acts taken in her judicial capacity, such as issuing rulings and dismissing prior actions, which barred Carlan’s damages claim even if the judge acted in error or maliciously. The practical consequence is that Carlan’s complaint remains dismissed, he receives no relief, and the district court’s judgment stands final. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.