Van de Kamp v. Goldstein (2008)
- Docket
- 07-854
- Decided
- 2008-01-01
Summary
Question: In a suit brought by a plaintiff alleging that he was wrongfully convicted of murder, are federal prosecutors entitled to absolute immunity against charges that they failed to satisfactorily share information regarding the testimony of a jailhouse informant during the course of the trial? Conclusion: Yes. In a unanimous opinion authored by Justice Stephen G. Breyer, the Supreme Court reversed the U.S. Court of Appeals for the Ninth Circuit. It reaffirmed its holding in Imbler that officers of the court are immune from liability "for actions intimately associated with the judicial phase of the criminal process." Acknowledging that immunity does not apply when officers of the court engage in administrative tasks, the Court reasoned that in Mr. Goldstein's case, the defendant prosecutors' failure to share information regarding the testimony of a jailhouse informant was predicated on a decision, requiring legal knowledge, made by those prosecutors about what information to share, and was thus not administrative. Rather, the decision not to share the information was intimately connected to their roles as officers of the court and therefore they were not subject to prosecution.