YouTuber, performance artist and proud Arizonian James “James Freeman” Springer lost another court battle in New Mexico last week as the United States Court of Appeals for the Tenth Circuit denied his appeal of his dismissal of his lawsuit against New Mexico’s Seventh Judicial District.
This lawsuit has raged on for years an originated when Springer attempted to film in a courthouse in New Mexico’s Seventh District. Springer turned his protests into a regular feature of his channel and was eventually banned from a single courthouse unless he had official business there and would later have it modified to the point where Springer was required to have a police escort while in the building.
Springer sued and capitalized on the situation, expanding his protests to courthouses throughout the Seventh District, which resulted in the order expanding to cover all the court facilities throughout the district.
The performance artist took great joy in singling out what he felt was the ridiculousness of the order. In at least one facility, due to locked doors, he would regularly have to march through a prohibited court owned area to get to a sheriff’s office to get a police escort to take him back through the prohibited area.
Springer’s natural rapport with deputies and police officers in New Mexico aided his cause, with most of the men he encountered shared similar beliefs with him. The indication from most police was that the order was stupid and they would often let Springer do what he wanted to with minimal resistance.
The lawsuit quietly raged on from June of 2023 until late May of 2024, when the court dismissed Springer’s second amended complaint. It left him with the ability to file a third amended complaint, which he declined to do. Instead, Springer attempted to appeal the case to the Tenth Circuit, but that court dismissed his claim since it did not have appellate jurisdiction.
Springer went back to the original court and demanded an order dismissing his second amended complaint, which was granted in October of 2024. The case now closed, he had standing to appeal the case to the court of appeals for the Tenth Circuit.
The case started in November of 2024 and meandered through the system until September of his year when the case was argued in open court. The final ruling was issued on November 7, 2025.
In the final ruling, written by Circuit Judge Harris L. Hartz, all of Springer’s accusations against New Mexico’s Seventh District Court and the employees of the courts were presumed true.
Even with that presumption, the court found that Springer did not have a case since he was suing employees in their official capacity.
Hartz wrote: “In the three counts against the Individual Defendants, Springer sought declaratory and injunctive relief only “for actions taken individually under the color of law.” Aplt. App. at 75–76. The district court read the second amended complaint as suing the individuals only in their personal capacities, and Springer has not contested that reading. Yet, “[u]nder § 1983, a plaintiff cannot sue an official in their individual capacity for injunctive or declaratory relief.” Chilcoat v. San Juan County, 41 F.4th 1196, 1214 (10th Cir. 2022).
Because we hold that the claims were improperly asserted against the Individual Defendants in their individual capacities, we need not address the other grounds relied on by the district court in dismissing Counts I, II, and III.”
Springer’s claim against the Seventh Judicial District was dismissed as the court felt that Springer could not overcome the Eleventh Amendment, which provides state sovereign immunity, which “ordinarily bars federal-court jurisdiction over private suits against a state by citizens of the state.”
In the end, Judge Hartz affirmed the district court’s order that dismissed the case.
It is unclear if Springer will appeal the decision.
