Van de Kamp v. Goldstein
The Supreme Court ruled that senior prosecutors cannot be sued for damages over how they trained deputies, supervised them, or set up (or failed to set up) office systems for tracking informant deals, because those tasks are closely tied to how criminal trials are run.
The unanimous decision extends the broad legal shield prosecutors already enjoyed for trial-related mistakes to cover office-wide training, supervision, and information-sharing failures, making it harder for wrongly convicted defendants to collect damages from prosecutors' offices even when systemic failures contributed to their convictions.
“We conclude that a prosecutor’s absolute immunity extends to all these claims.”
The Court's central holding that immunity covers training, supervision, and information-system claims.
How it got here: The trial court denied the prosecutors' request to dismiss on immunity grounds, the Ninth Circuit affirmed on interlocutory appeal, and the prosecutors asked the Supreme Court to review that ruling.
The Case in Depth
What happened
Thomas Goldstein spent 24 years in a California prison for murder based partly on testimony from a jailhouse informant who had secretly received reduced sentences for helping prosecutors in other cases. After a federal court freed him because prosecutors never disclosed those deals, Goldstein sued the county's former top prosecutors, claiming their office failed to train and supervise deputies and never built a system to track informants' benefits.
The question before the Court
Can a wrongfully convicted man sue the top prosecutors who ran his district attorney's office for failing to train staff or set up a system to share informant deals?
Why it matters
People who are wrongly convicted because prosecutors withheld evidence about unreliable witnesses generally cannot recover money damages from the supervisors who ran the office, even if better training or an information-tracking system might have prevented the error. The ruling shields prosecutorial offices nationwide from a broad category of civil-rights lawsuits over internal management failures.
What changes now
The Supreme Court's ruling is final on the immunity question, so Goldstein's supervision, training, and information-system claims are dismissed. The case is sent back to the lower courts for any further proceedings consistent with this ruling, though the immunity holding forecloses the specific claims the Court addressed. The decision also guides how other courts nationwide handle similar suits against supervisory prosecutors.
What this does not decide
The Court assumed, without deciding, that prosecutors actually have a constitutional duty to train, supervise, or maintain an informant-tracking system. It also did not decide whether Goldstein's underlying claim that his conviction was wrongful was correct — only that these particular defendants could not be sued for damages over it.
How the Court got there
The legal reasoning, step by step
- The Court applied the 'functional' test from its 1976 decision on prosecutorial immunity, which asks whether the specific conduct being challenged is intimately tied to preparing for and conducting a trial, rather than to unrelated administrative or investigative work; conduct that fits the trial-related category gets absolute protection from civil damages suits.
- The Court first reasoned through a hypothetical: if Goldstein had sued individual supervisors or colleagues directly for missing the informant's hidden deals in his specific trial, those prosecutors would clearly be immune, because that conduct is trial preparation. The Court found that switching the target from an individual prosecutor to a supervisor does not change this analysis.
- Applying that logic to training and supervision claims, the Court reasoned that decisions about what deputies should be taught regarding disclosing informant deals require legal judgment and are directly connected to how trials are conducted, making them functionally the same as an individual prosecutor's trial-related decisions.
- The Court also weighed practical consequences: allowing such suits would let defendants easily rewrite any claim of a trial error as a claim of inadequate training or supervision, would expose offices to liability years after the fact, and would treat trial prosecutors and their supervisors inconsistently for the same underlying conduct.
- Turning to the missing information system, the Court reasoned that deciding what informant information to include or exclude from an office database requires the same kind of legal judgment as training decisions, so a lawsuit over that gap would force courts to second-guess prosecutors' legal judgments about a specific trial.
- Because all three claims — training, supervision, and the information system — required scrutinizing legal judgments tied directly to how a specific trial was run, the Court concluded each fell within the scope of absolute immunity recognized in its earlier prosecutorial-immunity precedent.
Doctrinal impact
Cases affected by this decision
Reaffirms Imbler v. Pachtman (424 U. S. 409)
The Court relied on and extended Imbler's trial-related immunity test to cover office training, supervision, and information systems.