In the 1980 Supreme Court case Dennis v. Sparks et al., private individuals were found to be liable for conspiring with a state judge to violate another person's constitutional rights. The plaintiffs, oil well operators in Texas, alleged that the defendants bribed a state district judge to issue an injunction which shut down their wells. This was done so that the defendants could illegally pump and sell oil from those wells themselves. The court held that while judges are immune from liability for damages under Section 1983 of Title 42 of the United States Code (which provides recourse for deprivation of civil rights), private parties involved in such conspiracy are not protected by judicial immunity because they do not act under color of law.

In the dissenting opinion for Dennis v. Sparks, Justice William Rehnquist argued that private individuals who conspire with judges should not be granted immunity from prosecution under federal law. He contended that this interpretation of the law could potentially shield corrupt or unethical behavior by private citizens in collusion with public officials. The majority ruling held that a judge's absolute immunity extends to those private persons acting in concert with him, but Justice Rehnquist disagreed, stating it was an overreach and misinterpretation of precedent cases which only provided such protections to public officials performing their duties - not to private parties involved in potential corruption schemes.