Richard V. Moore v. Kimberly A. Crawford - Judicial Immunity Dismissal
Summary
The US District Court for the Middle District of Alabama dismissed with prejudice a pro se plaintiff's $5 million damages action against Circuit Court Judge Kimberly A. Crawford. The court adopted the Magistrate Judge's recommendation, finding that judicial immunity barred the claims because the plaintiff failed to establish the judge acted outside her judicial capacity or in the clear absence of all jurisdiction. The plaintiff's objections to the Magistrate Judge's report were overruled. This ruling affirms that state circuit judges are entitled to absolute judicial immunity from civil damages claims arising from their judicial acts.
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GovPing monitors US District Court MDAL Docket Feed for new courts & legal regulatory changes. Every update since tracking began is archived, classified, and available as free RSS or email alerts — 11 changes logged to date.
What changed
The court dismissed with prejudice a civil action in which plaintiff Richard V. Moore, proceeding pro se, sought $5 million in damages from Judge Kimberly A. Crawford arising from her dismissal of his child support modification request. The court upheld judicial immunity, finding the judge acted within her judicial capacity and jurisdiction. Pro se litigants filing civil damages claims against judicial officers should be aware that absolute judicial immunity protects judges from personal liability for judicial acts performed within their jurisdiction, regardless of whether the judge made a mistake or acted in error.
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Apr 26, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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March 31, 2026 Get Citation Alerts Download PDF Add Note
Richard V. Moore v. Kimberly A. Crawford
District Court, M.D. Alabama
- Citations: None known
- Docket Number: 1:25-cv-00126
Precedential Status: Unknown Status
Trial Court Document
IN THE UNITED STATES DISTRICT COURT
FOR THE MIDDLE DISTRICT OF ALABAMA
SOUTHERN DIVISION
RICHARD V. MOORE, )
)
Plaintiff, )
)
v. ) CASE NO. 1:26-cv-126-ECM
) [WO]
KIMBERLY A. CRAWFORD, )
)
Defendant. )
O R D E R
Plaintiff Richard V. Moore (“Moore”), who is proceeding pro se, brought this civil
action against Kimberly A. Crawford, Judge of the Circuit Court of Dale County, Alabama
(“Judge Crawford”), arising out of Judge Crawford’s dismissal of Moore’s request to
modify his child support obligation. (Doc. 1). In the amended complaint (the operative
complaint), Moore alleges that Judge Crawford denied him “equal protection of the law”
and violated his constitutional rights; Moore requests that the Court award him $5 million
in damages. (Doc. 10). On September 29, 2025, the Magistrate Judge recommended that
this case be dismissed with prejudice based on judicial immunity. (Doc. 14). Moore timely
filed objections to the Recommendation. (Doc. 16). After carefully reviewing the record
in this case, the Recommendation of the Magistrate Judge, and Moore’s objections, the
Court concludes that Moore’s objections are due to be overruled, the Recommendation of
the Magistrate Judge is due to be adopted, and this case is due to be dismissed with
prejudice.
When a party objects to a Magistrate Judge’s Report and Recommendation, the
district court must review the disputed portions de novo. 28 U.S.C. § 636 (b)(1); see also
United States v. Raddatz, 447 U.S. 667, 674 (1980). The district court “may accept, reject,
or modify, in whole or in part, the findings or recommendations made by the magistrate
judge[,] . . . receive further evidence[,] or recommit the matter to the magistrate judge with
instructions.” 28 U.S.C. § 636 (b)(1). De novo review requires that the district court
independently consider factual issues based on the record. Jeffrey S. by Ernest S. v. State
Bd. of Educ. of State of Ga., 896 F.2d 507, 513 (11th Cir. 1990). However, objections to
the Magistrate Judge’s Report and Recommendation must be sufficiently specific in order
to warrant de novo review. See LoConte v. Dugger, 847 F.2d 745, 750 (11th Cir. 1988)
(“Whenever any party files a timely and specific objection to a finding of fact by a
magistrate [judge], the district court has an obligation to conduct a de novo review of the
record with respect to that factual issue.”). Otherwise, a Report and Recommendation is
reviewed for clear error. See Macort v. Prem, Inc., 208 F. App’x 781, 784 (11th Cir. 2006).1
In his objections, Moore contends that Judge Crawford “acted in the clear absence
of all Good Faith.” (Doc. 16 at 1). Although he asserts that Judge Crawford committed
error in dismissing his child support action, he fails to establish that Judge Crawford was
not acting in her judicial capacity or that she acted in the clear absence of all jurisdiction.
See Sibley v. Lando, 437 F.3d 1067, 1070 (11th Cir. 2005) (per curiam); see also
McCullough v. Finley, 907 F.3d 1324, 1331 (11th Cir. 2018) (explaining that a judge is
1 While the Court recognizes that Macort is nonprecedential, the Court finds it persuasive.
2
entitled to absolute judicial immunity from damages “regardless of whether [she] made a
mistake, acted maliciously, or exceeded [her] authority”). Consequently, Moore’s
objections are due to be overruled.
Accordingly, upon an independent review of the record, and for good cause, it is
ORDERED as follows:
1. Moore’s objections (doc. 16) are OVERRULED;
2. The Recommendation of the Magistrate Judge (doc. 14) is ADOPTED, and
this case is DISMISSED with prejudice;
- All pending motions are DENIED as moot, and all pending deadlines are TERMINATED. A separate Final Judgment will be entered. DONE this 31st day of March, 2026.
/s/ Emily C. Marks
EMILY C. MARKS
UNITED STATES DISTRICT JUDGE
3
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