Van de Kamp v. Goldstein (Van de Kamp v Goldstein)

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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 _.

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.