Dennis v. Sparks

In Dennis v. Sparks (1980) 449 U.S. 24, the United States Supreme Court accepted, without discussion, that if a state actor is involved in the procurement of an injunction which violates the constitutional rights of the party enjoined, section 1983 may be invoked in an action for damages resulting from the injunction. However, Dennis is factually distinct from this case. In Dennis, the plaintiffs brought an action for damages under section 1983 against a state court judge and other individuals who allegedly conspired to bribe the judge to issue an injunction prohibiting the plaintiffs from producing minerals from certain oil leases, thus depriving the plaintiffs of property without due process of law. The defendants moved for dismissal, arguing that the judge was immune from damages for his official, albeit corrupt, acts, and that his dismissal from the action compelled the conclusion that the remaining defendants did not act under color of law. (Dennis, at pp. 25-26.) The Supreme Court held that although the judge was immune from damages because he acted within his official capacity, his intentional involvement in a conspiracy to obtain an injunction by corrupt means constituted state action, and the private parties who conspired with him acted "under color of law" within the meaning of section 1983. (Dennis, at pp. 27-30.)