## Facts

- Illinois law authorized Judge Howard Lee White to appoint and discharge adult and juvenile probation officers.
- In 1977, White hired Cynthia A. Forrester as an adult and juvenile probation officer.
- In 1979, White promoted Forrester to a supervisory project position in the juvenile court.
- In 1980, White demoted Forrester to a nonsupervisory position and later dismissed her.
- Forrester sued under 42 U.S.C. § 1983, alleging sex discrimination violating the Equal Protection Clause.
- A jury found sex discrimination and awarded Forrester compensatory damages.

## Issues

1. Whether a state-court judge has absolute judicial immunity from § 1983 damages liability for decisions to demote and discharge a subordinate court employee.
2. Whether such personnel decisions are judicial (adjudicative) acts or nonjudicial administrative acts for immunity purposes.

## Decision

- The Supreme Court unanimously reversed and remanded.
- The Court held that White’s decisions to demote and dismiss Forrester were administrative, not judicial, and therefore not protected by absolute judicial immunity.
- The Court indicated that qualified immunity may still be available for administrative conduct, depending on whether clearly established law was violated.

## Legal Principles

- Immunity analysis follows a functional approach: the nature of the act, not the official’s title, determines the scope of immunity.
- Absolute judicial immunity applies to judicial or adjudicative acts tied to resolving disputes in a judicial capacity.
- Administrative employment decisions by judges (including hiring, firing, and demotion) are treated like analogous executive personnel decisions and do not receive absolute immunity under § 1983.
- Absolute immunity is disfavored outside core adjudicative functions; qualified immunity and other protections generally address overdeterrence concerns for nonadjudicative tasks.

## Conclusion

A judge’s personnel decisions regarding court employees are administrative acts outside absolute judicial immunity, so § 1983 damages claims may proceed subject to any applicable qualified immunity defenses.


Forrester v. White, 484 U.S. 219 (1988)