A federal appeals court has upheld the dismissal of a lawsuit filed by Sabrina Zunker against Gilbert M. Roman, the former Chief Judge of the Colorado Court of Appeals. The Tenth Circuit Court of Appeals ruled on November 4, 2026, affirming the lower court's decision that Zunker’s claims were barred by sovereign immunity, which protects government officials from being sued for actions taken in their official capacity. This ruling is significant as it reinforces the principle of sovereign immunity and the limits of judicial accountability.

Sabrina Zunker, who represented herself in the case, alleged that the Colorado Court of Appeals violated her right to access the courts when it upheld a trial court's imposition of filing restrictions against her. The case was filed under 42 U.S.C. § 1983, a federal statute that allows individuals to sue for civil rights violations. Zunker’s complaint was dismissed by the district court for lack of subject matter jurisdiction, a decision that she appealed.

The dispute began when Zunker claimed that the restrictions placed on her filings amounted to an infringement of her rights. She believed that the court's actions were unjust and sought legal recourse. However, the magistrate judge recommended dismissal of her suit, stating that Judge Roman was entitled to sovereign immunity. The district court accepted this recommendation, leading to Zunker’s appeal to the Tenth Circuit.

The Tenth Circuit's ruling confirmed the lower court's decision, stating, "The state court judge was entitled to sovereign immunity." The court noted that Zunker did not challenge the immunity finding in her appeal, focusing instead on her request to amend her complaint. However, the court found that Zunker failed to provide sufficient reasoning to overturn the district court’s decision regarding the denial of her leave to amend her complaint. The judges on the panel included Circuit Judges Tymkovich, Phillips, and Federico.

The ruling emphasized that Zunker did not adequately explain why the district court's decision was erroneous. The court stated, "The first task of the appellant is to explain to us why the district court’s decision was wrong." Because Zunker did not fulfill this requirement, the Tenth Circuit affirmed the lower court's dismissal.

This ruling has implications for individuals seeking to challenge judicial decisions. It reinforces the idea that judges cannot be held liable for actions taken in their official capacities, which could deter similar lawsuits in the future. The decision also highlights the importance of properly objecting to findings in lower court proceedings, as Zunker conceded that she did not challenge the immunity finding in her original case.

The Tenth Circuit's decision may set a precedent for future cases involving claims against judges and other government officials, further solidifying the protections offered by sovereign immunity. This ruling could impact how individuals approach legal claims against state actors, particularly in cases where judicial immunity is a factor.

Moving forward, Zunker has limited options for further legal action. The court’s ruling is final, and while she could potentially seek a rehearing or file a different lawsuit, the barriers created by sovereign immunity remain significant. Details were not available in the court filing regarding any related cases or future actions Zunker may pursue.