Federal officials can ignore a state court order

This is an unusual case. Plaintiff alleges that while in custody in federal jail in Otisville, N.Y., he was suing Pennsylvania state officials for excessive force in the course of his arrest that landed him in Otisville. A state court judge in Pennsylvania ordered that Otisville officials transport him to a hearing in Pennsylvania so he could pursue his claim. The Otisville people did not comply with the transport order and plaintiff had to participate in the hearing by phone, not in person. Plaintiff sues the Otisville people for the constitutional (due process) violation of denying him the right to appear in person for his hearing; he claims the failure to comply with the state directive cause his excessive force case to be dismissed.

The case is Dixon v. Von Blanckensee, issued on April 12. Plaintiff loses the case on qualified immunity grounds because he does not plead a federal violation. The Supremacy Clause of the Constitution voids a mandatory state court order upon a federal official. States have no power to control the operations of federal officials, including the Bureau of Prisons. 

Plaintiff tries to get around the Supremacy Clause rule by arguing he was denied access to the courts. But that claim fails. You have a right to meaningful access to the courts, emphasis on meaningful. To win a case like this, plaintiff has to show the deprivation "hindered his efforts to pursue a legal claim. The Second Circuit (Lynch, Bianco and Halpern [D.J.]) notes that plaintiff has abandoned any claim that defendant prevented him from participating in the state court hearing. Rather, he was able particulate in the hearing remotely, and his rights were not prejudiced as a result of the remote proceeding. And any claim that defendant caused his case to be dismissed is too conclusory to survive a motion to dismiss.  

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