Van de Kamp v. Goldstein
Citations
- 555 U.S. 335
- 129 S. Ct. 855
- 172 L. Ed. 2d 706
- 2009 U.S. LEXIS 1003
About this case
From Wikipedia, the free encyclopedia
2009 United States Supreme Court case
Van de Kamp v. Goldstein, 555 U.S. 335 (2009), was a United States Supreme Court case in which the court held that prosecutors are absolutely immune from suit under 42 U.S.C. § 1983 based on management tasks such as their supervision or training of subordinates and their information-system organization. Particularly, the lead prosecutor in this case was immune from suit for improperly supervising the disclosures made by line prosecutors pursuant to _Brady v. Maryland _.[1]
Background
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Thomas Goldstein was released from a California prison after he filed a successful federal _habeas _ petition alleging that his murder conviction depended, in critical part, on the false testimony of a jailhouse informant (Fink), who had received reduced sentences for providing prosecutors with favorable testimony in other cases; that prosecutors knew, but failed to give his attorney, this potential impeachment information; and that, among other things, that failure had led to his erroneous conviction. Once released, Goldstein filed this suit under 42 U. S. C. §1983, asserting the prosecution violated its constitutional duty to communicate impeachment information under _Giglio v. United States _ due to the failure of petitioners, supervisory prosecutors, to properly train or supervise prosecutors or to establish an information system containing potential impeachment material about informants. Claiming absolute immunity , the prosecutors asked the federal District Court to dismiss the complaint, but the court declined, finding that the conduct was "administrative," not "prosecutorial," and hence fell outside the scope of an absolute immunity claim. The Ninth Circuit Court of Appeals , on interlocutory appeal , affirmed.
Opinion of the court
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The Supreme Court issued an opinion on January 26, 2009.[1]
Later developments
[(https://en.wikipedia.org/w/index.php?title=Van_de_Kamp_v._Goldstein&action=edit§ion=3 "Edit section: Later developments")
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References
[(https://en.wikipedia.org/w/index.php?title=Van_de_Kamp_v._Goldstein&action=edit§ion=4 "Edit section: References")
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External links
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- Text of Van de Kamp v. Goldstein, 555 U.S. 335 (2009) is available from: Internet Archive (docket files) Justia
This article incorporates written opinion of a United States federal court . As a work of the U.S. federal government , the text is in the **public domain **.
Retrieved from "https://en.wikipedia.org/w/index.php?title=Van_de_Kamp_v._Goldstein&oldid=1351977420 "
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How courts have described this case
Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.
- holding that in a § 1983 action, “the immunity that the law grants prosecutors [for actions intimately associated with initiation, prosecution and punishment in a criminal case] is ‘absolute.’”
- noting that Goldstein was granted habeas relief when it was revealed that a 1980s California jailhouse informant had not disclosed that his sentence was reduced in return for testimony
- recognizing absolute prosecutorial immunity from suit under Section 1983 for all actions taken in capacity as officers of the court
- finding that prosecutors are absolutely immune from suit in connection with performing “administrative obligation[s] [that are] directly connected with the conduct of a trial”
- stating that, although the supervision of prosecutors is an administrative function, it is “directly connected with the conduct of a trial”
- noting that a prosecutor acting as “an officer of the court” is absolutely immune from a suit seeking monetary damages
Source: CourtListener parenthetical corpus (CC0).
Judges: Breyer
Read full opinion on CourtListenerSourced from CourtListener / Free Law Project (CC0).
This is legal information, not legal advice. Laws vary by jurisdiction and change frequently. Always verify current law with official sources and consult a licensed attorney in your jurisdiction for advice on your specific situation.