Imbler v. Pachtman
424 U.S. 409 (1976)
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Rule of Law:
A state prosecutor has absolute immunity from a civil suit for damages under 42 U.S.C. § 1983 for actions taken while initiating a prosecution and presenting the State's case, as those actions are intimately associated with the judicial phase of the criminal process.
Facts:
- In January 1961, two men robbed a Los Angeles market, during which one of them shot and killed the owner, Morris Hasson.
- Ten days later, Leonard Lingo was killed during another robbery attempt in Pomona, and his accomplice, Paul Imbler, later turned himself in for that crime.
- Based on an investigation, the Los Angeles District Attorney's office came to believe Imbler and Lingo had also committed the Hasson robbery and that Imbler was the gunman.
- Imbler was charged with the murder of Hasson.
- At trial, the state's case against Imbler relied heavily on the eyewitness testimony of Alfred Costello, who positively identified Imbler as the shooter.
- Imbler presented an alibi defense, which was corroborated by another accomplice from the Pomona robbery.
- After Imbler's conviction, the trial prosecutor, Richard Pachtman, discovered new evidence that both corroborated Imbler's alibi and undermined the credibility of the key witness, Costello.
- Pachtman wrote a letter to the Governor of California disclosing this newly discovered evidence.
Procedural Posture:
- A California jury found Paul Imbler guilty of first-degree felony murder and sentenced him to death.
- On direct appeal, the Supreme Court of California affirmed the conviction and sentence.
- Imbler filed a state habeas corpus petition based on newly discovered evidence, but the Supreme Court of California denied the writ.
- In a separate proceeding, Imbler's death sentence was overturned on unrelated grounds, and his sentence was commuted to life imprisonment.
- Imbler then filed a habeas corpus petition in the U.S. District Court for the Central District of California, which granted the writ, finding cumulative instances of prosecutorial misconduct.
- The U.S. Court of Appeals for the Ninth Circuit affirmed the District Court's grant of habeas corpus, and Imbler was released after California declined to retry him.
- Imbler filed a civil rights action under 42 U.S.C. § 1983 in federal district court against prosecutor Richard Pachtman and others.
- The District Court granted Pachtman's motion to dismiss the complaint on the grounds of prosecutorial immunity.
- Imbler, the appellant, appealed to the U.S. Court of Appeals for the Ninth Circuit, which affirmed the dismissal in favor of Pachtman, the appellee.
- The U.S. Supreme Court granted Imbler's petition for certiorari.
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Issue:
Does a state prosecuting attorney who acted within the scope of his duties in initiating and pursuing a criminal prosecution have absolute immunity from a civil suit for damages under 42 U.S.C. § 1983 for alleged deprivations of the defendant's constitutional rights?
Opinions:
Majority - Justice Powell
Yes, a state prosecutor acting within the scope of their duties in initiating and presenting the state's case is absolutely immune from a § 1983 suit for damages. The Court reasoned that § 1983 must be read in harmony with the common law, which traditionally afforded prosecutors absolute immunity for malicious prosecution. This immunity is grounded in public policy to prevent harassment by unfounded litigation, avoid deflecting the prosecutor's energy from public duties, and ensure prosecutors can exercise independent judgment without fear of personal liability. A qualified immunity would be insufficient, as the threat of litigation would undermine the prosecutor's performance, lead to a 'virtual retrial' of the criminal case in a civil forum, and could skew post-conviction judicial decisions. The Court emphasized that this absolute immunity applies to a prosecutor's acts that are 'intimately associated with the judicial phase of the criminal process,' distinguishing them from administrative or investigative functions.
Concurring - Justice White
Yes, but this immunity should be limited. While agreeing that absolute immunity is appropriate for claims of malicious prosecution or knowingly using perjured testimony, the concurrence argues that it should not extend to the unconstitutional suppression of exculpatory evidence. Granting immunity for using false testimony encourages prosecutors to present all evidence to the court, letting the judicial process determine the truth. Conversely, granting immunity for suppressing evidence would discourage the disclosure of information and harm the judicial process. The concurrence joins the judgment only because Imbler's complaint was primarily based on the knowing use of false testimony and failed to adequately allege a constitutional claim for suppression of evidence.
Analysis:
This case firmly establishes the doctrine of absolute prosecutorial immunity under § 1983 for a prosecutor's core advocacy functions. The decision insulates prosecutors from civil liability for their conduct in deciding to prosecute and in presenting evidence in court, treating these actions as 'quasi-judicial.' By adopting a functional approach, the Court created a distinction between a prosecutor's role as an advocate (which receives absolute immunity) and their role as an administrator or investigator (which may only receive qualified immunity). This decision set the stage for subsequent cases that have struggled to define the precise boundary between these protected and unprotected functions.
