Van de Kamp v. Goldstein - 555 U.S. 335, 129 S. Ct. 855 (2009)

Rule:

Regarding prosecutorial actions that are intimately associated with the judicial phase of the criminal process, prosecutors are absolutely immune from liability in 42 U.S.C.S. § 1983 lawsuits brought under such circumstances.

Facts:

Respondent Goldstein was released from a California prison after he filed a successful federal habeas petition alleging that his murder conviction depended, in critical part, on the false testimony of a jailhouse informant who had received reduced sentences for providing prosecutors with favorable testimony in other cases; that prosecutors knew, but failed to give his attorney, this potential impeachment information; and that, among other things, that failure had led to his erroneous conviction. Once released, Goldstein filed this suit under 42 U.S.C. § 1983, asserting the prosecution violated its constitutional duty to communicate impeachment information, due to the failure of petitioners, supervisory prosecutors, to properly train or supervise prosecutors or to establish an information system containing potential impeachment material about informants. Claiming absolute immunity, petitioners asked the District Court to dismiss the complaint, but the court declined, finding that the conduct was "administrative," not "prosecutorial," and hence fell outside the scope of an absolute immunity claim. The Ninth Circuit, on interlocutory appeal, affirmed.

Issue:

Were the former district attorney and deputy district attorney entitled to absolute immunity from 42 U.S.C.S. § 1983 action asserting that supervision, training, or information-system management that they provided was constitutionally inadequate?

Answer:

Yes.

Conclusion:

The Supreme Court determined that petitioners were entitled to absolute immunity in respect to the former inmate's claims that their supervision, training, or information-system management was constitutionally inadequate because the management tasks at issue concerned how and when to make impeachment information available at trial and were thereby directly connected with a prosecutor's basic trial advocacy duties.