Hartman v. Moore
Headline: Court requires proof that criminal charges lacked probable cause before allowing lawsuits against government investigators for retaliatory prosecutions, making it harder to win such suits.
Holding: A plaintiff who says government investigators induced a retaliatory criminal prosecution must allege and prove the underlying charges were brought without probable cause to establish causation and recover damages.
- Requires plaintiffs to prove lack of probable cause to sue investigators for retaliatory prosecution.
- Makes it harder to obtain damages for retaliatory prosecutions.
- Resolves conflicting appeals court rules about such suits nationwide.
Summary
Background
William Moore was the chief executive of a company that built multiline mail-sorting machines. He lobbied the Postal Service to adopt that technology but his firm lost a large contract. Postal inspectors investigated Moore and his company and urged a federal prosecutor to bring criminal charges. A jury trial ended in acquittal because the trial judge found a lack of direct evidence. Moore then sued the inspectors and the prosecutor, claiming they had engineered the prosecution in retaliation for his lobbying.
Reasoning
The Court addressed whether a plaintiff may sue investigators for provoking a retaliatory prosecution without showing the underlying charges lacked probable cause (a reasonable basis to charge someone with a crime). The Court said no. It explained that a plaintiff must prove that retaliation, not legitimate reasons, was the but-for cause of prosecution. Because investigators are not the prosecutors and prosecutors enjoy a presumption of regularity, evidence that the charges themselves lacked probable cause is powerful circumstantial proof that inducement caused the prosecution.
Real world impact
The ruling makes it harder for people to win damages against investigators who press for prosecutions in anger or revenge: plaintiffs now must prove the prosecutor lacked probable cause to charge them. This legal rule will be raised in future retaliatory-prosecution suits and may reduce the number of successful claims. The decision resolves a split among federal appeals courts about this requirement.
Dissents or concurrances
Justice Ginsburg dissented, saying the Court of Appeals correctly placed the burden on the investigators to show they would have pursued the case absent retaliatory motive, warning that the majority’s rule could let weak-but-not-baseless prosecutions go unchecked.
Opinions in this case:
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