Van de Kamp v. Goldstein
555 U.S. 335, 172 L. Ed. 2d 706, 2009 U.S. LEXIS 1003 (2009)
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Rule of Law:
Absolute prosecutorial immunity extends to claims that supervisory prosecutors failed to adequately train or supervise subordinates, or failed to establish information systems, regarding their constitutional obligation to disclose impeachment evidence.
Facts:
- In 1980, Thomas Goldstein was convicted of murder in a California state court.
- His conviction relied heavily on the testimony of a jailhouse informant, Edward Floyd Fink.
- Fink's testimony was later determined to be false.
- In exchange for favorable testimony in past cases, Fink had previously received reduced sentences from the Los Angeles County District Attorney’s Office.
- The District Attorney's office possessed this information about the benefits provided to Fink.
- Prosecutors in the office failed to disclose this potential impeachment information to Goldstein's defense attorney during his trial.
- As a result of his conviction, Goldstein served 24 years in prison.
Procedural Posture:
- Thomas Goldstein filed a habeas corpus petition in the U.S. District Court for the Central District of California.
- The District Court granted the habeas petition, ordering the State to either retry Goldstein or release him.
- The U.S. Court of Appeals for the Ninth Circuit affirmed the District Court's order.
- The State chose to release Goldstein rather than retry him.
- Upon his release, Goldstein filed a 42 U.S.C. § 1983 civil rights lawsuit in U.S. District Court against the former Los Angeles County District Attorney and his chief deputy.
- The defendants filed a motion to dismiss the complaint, asserting absolute prosecutorial immunity.
- The District Court denied the motion to dismiss.
- The defendants (appellants) filed an interlocutory appeal to the U.S. Court of Appeals for the Ninth Circuit, which affirmed the District Court's denial of immunity, holding that the claims concerned administrative, not prosecutorial, conduct.
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Issue:
Does a prosecutor's absolute immunity from a § 1983 damages claim extend to administrative failures, such as inadequate training, supervision, or information management, that are alleged to have caused a constitutional violation in a specific criminal trial?
Opinions:
Majority - Justice Breyer
Yes. A prosecutor's absolute immunity extends to administrative failures directly connected with the judicial phase of the criminal process. The Court applied the functional approach from Imbler v. Pachtman, which grants absolute immunity for actions 'intimately associated with the judicial phase of the criminal process.' The Court reasoned that claims of failure to train, supervise, or maintain information systems concerning disclosure obligations are not like purely administrative tasks such as hiring or payroll. Instead, they are directly connected with trial conduct because they concern how evidence is gathered and handled for trial, require legal knowledge and discretion, and are inextricably linked to a specific alleged trial error. Allowing such suits would create the same dangers Imbler sought to avoid: deterring vigorous prosecution, deflecting prosecutors' energies, and allowing plaintiffs to easily re-plead a trial-level error as an administrative failure to circumvent immunity.
Analysis:
This decision significantly expands the scope of absolute prosecutorial immunity by shielding not just trial advocacy but also related administrative functions. It makes it extremely difficult for wrongfully convicted individuals to hold supervisory prosecutors or their offices civilly liable for systemic failures that lead to constitutional violations like Brady or Giglio violations. By characterizing training and information management as part of the prosecutorial function, the Court effectively closed a potential avenue for § 1983 liability, prioritizing the independence of prosecutorial offices over providing a remedy for this type of official misconduct. Future cases challenging prosecutorial misconduct will likely have to distinguish their claims from these types of trial-related administrative functions to survive a motion to dismiss.
