Van De Kamp v. Goldstein

129 S.Ct. 855 (2009)

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Holding & Decision

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Nature Of The Case

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Facts

Goldstein (P) filed a habeas corpus action claiming that in 1980 he was convicted of murder; that his conviction depended in critical part upon the testimony of Fink, a jailhouse informant; that Fink's testimony was unreliable, indeed false; that Fink had previously received reduced sentences for providing prosecutors with favorable testimony in other cases and that prosecutors in the D.A's Office knew about the favorable treatment; that the office had not provided P's attorney with that information; and that, among other things, the prosecution's failure to provide P's attorney with this potential impeachment information had led to his erroneous conviction. The court agreed with P and ordered the State either to grant P a new trial or to release him. The Court of Appeals affirmed. The State decided that, rather than retry P who had already served 24 years of his sentence, it would release him. P filed this § 1983 action against Ds, the former Los Angeles County district attorney and chief deputy district attorney. Ds, claiming absolute immunity. The District Court denied the motion to dismiss on the ground that the conduct asserted amounted to 'administrative,' not 'prosecutorial,' conduct; hence it fell outside the scope of the prosecutor's absolute immunity to § 1983 claims. The Ninth Circuit affirmed the District Court's 'no immunity' determination. The Supreme Court granted certiorari.

Issues

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Legal Analysis

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