Van de Kamp v. Goldstein

Supreme Court of the United States · Torts

TortsSection 1983Prosecutorial Immunityabsolute immunityprosecutor§ 1983GiglioBrady

Facts

Goldstein alleged that his 1980 murder conviction depended critically on testimony from Edward Floyd Fink, a jailhouse informant whose testimony was false and unreliable. He further alleged that Fink had previously received reduced sentences in exchange for favorable testimony, that at least some prosecutors in the Los Angeles County District Attorney's Office knew of that favorable treatment, and that this impeachment information was not disclosed to his defense counsel. In this § 1983 action, Goldstein did not sue only over the trial nondisclosure itself; he alleged that the nondisclosure resulted from the chief supervisory prosecutors' failure adequately to train and supervise prosecutors and their failure to establish an information system containing impeachment material about informants.

Issue

Does a prosecutor's absolute immunity from § 1983 damages liability extend to claims that supervisory prosecutors failed to train or supervise line prosecutors, or failed to create a trial-related information system, where those failures allegedly caused a Giglio violation at the plaintiff's criminal trial?

Rule

Under the functional approach to prosecutorial immunity, absolute immunity applies not only to a prosecutor's conduct in preparing for and presenting a case, but also to supervisory, training, and trial-related information-system management claims when those administrative obligations are directly connected with the conduct of a trial, require legal knowledge and related discretion, and the § 1983 claim necessarily depends on an individual prosecutor's constitutional error at the plaintiff's trial.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Cleveland, Omar Vega spent 18 years in prison before his conviction was vacated because the trial prosecutor failed to disclose impeachment material about a paid jail informant. Vega then sued the elected head of the county prosecutor's office under § 1983, alleging the office never trained assistants on when impeachment information about informants had to be disclosed to the defense.

Is the elected prosecutor most likely absolutely immune from Vega's damages claim?

Explanation. Absolute immunity applies under the functional approach when the challenged supervisory or training obligation is directly connected with the conduct of a trial, requires legal knowledge and discretion, and the § 1983 claim necessarily depends on an individual prosecutor's constitutional error at the plaintiff's trial. A claim that supervisors failed to train assistants on disclosure of impeachment material fits that description. The majority rejected the argument that labeling the conduct 'administrative' defeats immunity where the task is closely tied to trial advocacy.