Carlock v. Harper Woods, City of et al

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF MICHIGAN
SOUTHERN DIVISION
JAMES CARLOCK, on behalf of
himself and all others similarly situated,
Plaintiff,
v.
CITY OF HARPER WOODS, et al.,
Defendants.
Case No. 24-cv-11122
Honorable Robert J. White
OPINION AND ORDER GRANTING 32A DISTRICT COURT’S
MOTION TO PARTIALLY DISMISS THE COMPLAINT
I. Introduction
James Carlock commenced this putative 42 U.S.C. § 1983 class action against,
among others, Michigan’s 32A District Court. The complaint alleges that Chief
Judge Rebekah Coleman’s bail orders and the court’s arraignment policies and
practices violate the Fourteenth Amendment to the United States Constitution.
Before the Court is 32A District Court’s motion to dismiss the claims asserted
against it in the complaint. (ECF No. 24). Carlock responded in opposition. (ECF
No. 26). 32A District Court filed a reply. (ECF No. 27). The Court will decide the
motion without a hearing pursuant to E.D. Mich. LR 7.1(f)(2). For the following
reasons, the motion is granted.
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II. Background
A. Factual History
Harper Woods detectives arrested Carlock in July 2021 after he allegedly
doused his then-girlfriend with gasoline and lit her arm on fire. (ECF No. 1,
PageID.9-10, 13, ¶¶ 21, 26, 40). The Wayne County Prosecutor’s Office charged
him with, among other things, assault with intent to murder. (Id., PageID.15, ¶ 49;
ECF No. 11-2, PageID.155). Carlock pleaded not guilty at his arraignment. (ECF
No. 1, PageID.18, ¶ 58; ECF No. 11-2, PageID.55). 32A District Court Chief Judge
Rebekah Coleman set a secured cash bond condition in the amount of $150,000.
(ECF No. 1, PageID.18, ¶ 61; ECF No. 11-3, PageID.159). Carlock asserts that
Chief Judge Coleman never evaluated his financial “ability to post a bond,” his risk
of flight, whether he posed an unreasonable risk of danger to the community, or
whether “non-financial” conditions would ameliorate these risks. (ECF No. 1,
PageID.19, 22, ¶¶ 64, 79).
Chief Judge Coleman retained the secured cash bond conditions after binding
Carlock over to the Wayne County Circuit Court. (Id., PageID.19, ¶ 67). The state
circuit court maintained those bond conditions pending trial. (Id., ¶ 68).
A jury acquitted Carlock of all the charged offenses on September 28, 2023
after a four-day trial. (Id., PageID.21, ¶ 75; ECF No. 11-2, PageID.157). By that
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time, he had spent over two years in pretrial detention at the Wayne County Jail
because he could not afford to post bond. (ECF No. 1, PageID.21, 26, ¶¶ 76, 95-96).
B. Procedural History
Carlock filed this 42 U.S.C. § 1983 lawsuit alleging both individual and
putative classwide causes of action. The individual claims are asserted solely against
the City of Harper Woods and the police officers who arrested Carlock and
investigated the charged offenses. (Id., PageID.49-61, ¶¶ 153-214).
The classwide claims are asserted against Wayne County and 32A District
Court.1 Carlock contends that Chief Judge Coleman’s bail orders violate the
Fourteenth Amendment’s Equal Protection Clause, as well as substantive and
procedural due process guarantees, because she fails to make an individualized
determination about each defendant’s ability to pay bail, their risk of flight and
danger to the community, and whether any non-financial conditions would address
these risks. (Id., PageID.22, 24-25, 62-70, ¶¶ 79, 88-90, 215-38).
32A District Court now moves to dismiss these classwide claims (Class
Counts 1-3) on the ground that the Eleventh Amendment to the United States
Constitution bars Carlock from obtaining injunctive relief against the court. (ECF
No. 24).
1 The Court already dismissed Wayne County from this lawsuit. (ECF No. 25).
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III. Legal Standards
Fed. R. Civ. P. 12(b)(1) provides for the dismissal of an action where the
district court lacks subject matter jurisdiction. Rule 12(b)(1) motions for lack of
subject matter jurisdiction may challenge either (1) the facial sufficiency of the
pleading itself, or (2) the factual grounds for invoking subject matter jurisdiction.
United States v. Ritchie, 15 F.3d 592, 598 (6th Cir. 1994). Facial challenges address
whether the pleading alleges a basis for subject matter jurisdiction. The Court views
the pleading’s allegations as true and construes them in the light most favorable to
the nonmoving party. Id.
“Dismissals under Eleventh Amendment immunity . . . come under Rule
12(b)(1), which covers dismissals for lack of subject-matter jurisdiction.” Crump v.
Blue, 121 F.4th 1108, 1113 (6th Cir. 2024) (quotation omitted); see also WCI, Inc.
v. Ohio Dep’t of Pub. Safety, 18 F.4th 509, 513 (6th Cir. 2021) (stating that Eleventh
Amendment immunity “sounds in subject-matter jurisdiction.”). And the party
“asserting Eleventh Amendment immunity has the burden to show that it is entitled
to immunity, i.e., that it is an arm of the state.” Lowe v. Hamilton County Dep’t of
Job & Family Servs., 610 F.3d 321, 324 (6th Cir. 2010) (quotation omitted); see also
Gragg v. Ky. Cabinet for Workforce Dev., 289 F.3d 958, 963 (6th Cir. 2002).
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IV. Analysis
The Eleventh Amendment to the United States Constitution prohibits a suit
brought in federal court against a state, its agencies, or state officials acting in their
official capacities unless the state has expressly waived its sovereign immunity or
unequivocally consented to be sued. U.S. Const. amend. XI; see also Will v. Mich.
Dep’t of State Police, 491 U.S. 58, 66 (1989); Cady v. Arenac County, 574 F.3d 334,
342-43 (6th Cir. 2009). The State of Michigan has not waived its sovereign
immunity or consented to be sued in federal court. Johnson v. Dellatifa, 357 F.3d
539, 545 (6th Cir. 2004); see also Abick v. Michigan, 803 F.2d 874, 877 (6th Cir.
1986).
The question presented here is whether 32A District Court is an “arm of the
state” and, therefore, entitled to Eleventh Amendment immunity from Carlock’s suit.
In Pucci v. Nineteenth Dist. Court, 628 F.3d 752, 762 (6th Cir. 2010), the United
States Court of Appeals for the Sixth Circuit expressly held that “Michigan’s district
courts, including the Nineteenth District Court, are arms of the state for sovereign-
immunity purposes.” That means Eleventh Amendment immunity precludes
lawsuits against Michigan district courts “for injunctive, declaratory or monetary
relief.” Morgan v. Bd. of Prof’l Responsibility of the Supreme Court of Tennessee,
63 F.4th 510, 515 (6th Cir. 2024) (quotation omitted); see also Dolan v. City of Ann
Arbor, 407 F. App’x 45, 46-47 (6th Cir. 2011) (affirming dismissal of Michigan’s
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Fifteenth District Court on Eleventh Amendment immunity grounds); Brownlee v.
41B Dist. Ct., No. 24-12745, 2025 U.S. Dist. LEXIS 186874, at *9-15 (E.D. Mich.
Sep. 23, 2025) (holding that Michigan’s 41B District Court is entitled to Eleventh
Amendment immunity).
Carlock resists this outcome. He maintains that the constitutional claims
asserted against 32A District Court fall within the Ex parte Young, 209 U.S. 123
(1908) exception to Eleventh Amendment immunity. According to Ex parte Young,
“suits against state officials seeking equitable relief for ongoing violations of federal
law are not barred by the Eleventh Amendment.” Morgan, 63 F.4th at 515 (quotation
omitted) (emphasis added). But Carlock is not suing state officials in their official
capacity for ongoing violations of federal law. He instead named the district court
itself as a party defendant. And Ex parte Young’s exception to Eleventh Amendment
immunity is inapplicable to claims asserted against state entities as opposed to state
officials. See Morgan, 63 F.4th at 517 (“One prerequisite for the Ex parte Young
exception to apply is that the claimant must explicitly allege that a state official acted
in her official capacity.”); see also Long v. Tennessee, 744 F. App’x 945, 946 (6th
Cir. 2018) (holding that the plaintiff’s “failure to allege an official-capacity claim
against a state official prevents him from availing himself of the Ex parte Young
exception.”).
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Because Eleventh Amendment immunity bars Carlock’s classwide claims
against 32A District Court (Class Counts 1-3), those causes of action are subject to
Rule 12(b)(1) dismissal. Accordingly,
IT IS ORDERED that 32A District Court’s motion to partially dismiss the
complaint (ECF No. 24) is granted.
IT IS FURTHER ORDERED that the Clerk of the Court is directed to
terminate 32A District Court from the docket as a party defendant to this action.
Dated: November 20, 2025 s/ Robert J. White
Robert J. White
United States District Judge
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