In the case of Forrester v. White, the U.S. Supreme Court ruled in 1987 that judges do not have absolute immunity from liability for damages when they act in an administrative capacity, such as hiring and firing court personnel. The case arose after a state judge dismissed a female probation officer without cause or notice, allegedly due to gender discrimination. The former employee sued under Title VII of the Civil Rights Act and won at trial level but lost on appeal because it was determined that judges had absolute immunity from lawsuits related to their judicial functions. However, upon reaching the Supreme Court, this ruling was overturned with a 5-4 decision stating that while judges are immune from suits relating to their judicial actions (to ensure independence), this does not extend to administrative duties like employment decisions.

In the dissenting opinion for Forrester v. White, Justice Blackmun argued that judicial immunity should extend to judges' administrative decisions related to their judicial functions. He contended that a judge's role in personnel management is integral to his or her ability to perform judicial duties effectively and thus should be protected by absolute immunity. According to him, this case was not about protecting incompetent judges but preserving an independent judiciary free from potential harassment and intimidation through litigation. He also expressed concern over the majority's distinction between 'judicial acts' and 'administrative acts', arguing it could lead courts into uncharted waters of determining which tasks are essential enough for a judge’s role warranting absolute immunity protection.