## Facts

- Ronnie Hawkins, a criminal defendant in Los Angeles County, was tried before Judge Joan Comparet-Cassani and convicted of felony burglary and felony theft.
- At a subsequent hearing for sentencing and related matters, the Sheriff’s Department placed an electronic “stun belt” on Hawkins pursuant to a court order issued after reported threats against the court.
- Hawkins alleged the belt delivered a 50,000-volt shock and caused severe pain and other physical effects; he further alleged that the threat of activation intimidated him and impaired his ability to participate in proceedings.
- During the hearing, after Hawkins allegedly made out-of-order statements and was disruptive, Judge Comparet-Cassani ordered a deputy to activate the belt.
- Hawkins brought a federal civil rights action under 42 U.S.C. § 1983 seeking damages, declaratory relief, and an injunction against the use or threatened use of stun belts in Los Angeles County courts; he also asserted claims framed in part by international-law concepts (e.g., torture and cruel treatment).
- Hawkins sought to represent a class of criminal defendants in Los Angeles County courts who were subjected to, or threatened with, stun-belt use.

## Issues

1. Whether the claims against the judge, state-court entities, the sheriff, and the county should be dismissed based on doctrines such as absolute judicial immunity, Eleventh Amendment immunity, and failure to state a claim.
2. Whether a class challenging a countywide policy and practice of using stun belts in criminal court proceedings satisfied the requirements of Federal Rule of Civil Procedure 23.
3. Whether the plaintiff and class were entitled to preliminary injunctive relief barring use of stun belts under the challenged conditions based on likely constitutional violations and irreparable harm.

## Decision

- The court granted in part and denied in part the motion to dismiss, dismissing certain claims/defendants on immunity and related grounds while allowing core constitutional policy-and-practice claims to proceed.
- The court granted class certification, certifying a class of Los Angeles County criminal defendants subjected to or threatened with stun-belt use for purposes of declaratory and injunctive relief.
- The court granted a preliminary injunction restraining the challenged use of stun belts, finding a strong showing on the merits and irreparable harm, with equities and public interest favoring relief.

## Legal Principles

- Absolute judicial immunity generally bars damages claims against a judge for acts taken in a judicial capacity, even if the acts are alleged to be unconstitutional.
- State-court entities may be immune from certain federal claims under Eleventh Amendment and related “arm of the state” doctrines, limiting available defendants and remedies.
- A policy or practice of imposing and remotely activating high-voltage electronic restraints in the courtroom can plausibly constitute excessive force and violate the Eighth and/or Fourteenth Amendments, particularly when used to control courtroom behavior rather than to respond to immediate violent threats.
- The threat of painful restraint that chills a defendant’s ability to speak, consult counsel, or participate in proceedings is relevant to the constitutional analysis and to irreparable harm.
- Rule 23(b)(2) certification is appropriate where defendants act or refuse to act on grounds generally applicable to the class and the primary relief sought is injunctive or declaratory.
- Preliminary injunctive relief may issue upon a sufficient showing of likely success (or serious questions), irreparable harm, a favorable balance of hardships, and consistency with the public interest.

## Conclusion

The court limited the case through immunity-based dismissals but allowed the central § 1983 challenge to proceed, certified a class seeking forward-looking relief, and preliminarily enjoined the challenged courtroom use of stun belts due to the risk of unconstitutional excessive force and irreparable interference with defendants’ bodily integrity and participation in criminal proceedings.


Hawkins v. Comparet-Cassani, 33 F. Supp. 2d 1244 (C.D. Cal. 1999)