Van de Kamp v. Goldstein, 07-854
01/26/09, U.S.
Holding: Absolute immunity protects supervisory prosecutors from civil rights lawsuits claiming that they failed to properly train and supervise subordinates in providing criminal defendants with potential impeachment material about confidential informers or to establish an information system for managing such information. Here, after Goldstein served 24 years in prison for murder conviction, he was released based upon a court finding that the jailhouse informant had been given favorable treatment for his information, but that fact was never shared–as it should have been–with Goldstein’s defense lawyer. Goldstein then brought a civil rights lawsuit, claiming in part that supervising prosecutors failed to train and supervise subordinates regarding disclosure of constitutionally required information to criminal defendants and failed to create a system for retaining and sharing information about informants. The two top prosecutors lost their bid for immunity in the Ninth Circuit.
Court held that training, supervision and information-sharing are not “administrative,” in the sense of lacking legal immunity, but instead are “intimately associated with the judicial phase of the criminal process.” Thus, supervisors’ failure to perform such tasks satisfactorily cannot give rise to liability for damages. See Imbler v. Pachtman, 424 U.S. 409 (1976); Buckley v. Fitzsimmons, 509 U.S. 259 (1993). Held, judgment reversed and remanded.
