Van de Kamp v. Goldstein

Background

A man convicted of murder in 1980 said his trial relied on false testimony from a jailhouse informant who had received sentence reductions for favorable testimony. He later won federal habeas relief and was released. After release he sued former county prosecutors, saying they violated his rights by not disclosing the informant’s deals and by failing to train, supervise, or create an office system to record such information.

Reasoning

The Court reviewed whether prosecutors enjoy absolute immunity from money-damage suits for claims about training, supervision, or running an information system. Relying on prior decisions that protect prosecutors when they act as courtroom advocates, the Court applied a functional test. It concluded these supervisory and information decisions are closely tied to trial advocacy because they concern what evidence reaches a jury and require legal judgment about what belongs in training or records. Allowing damages suits would risk chilling prosecutors’ trial decisions, create anomalies between trial prosecutors and supervisors, and force courts to review many office-level legal choices.

Real world impact

The Court reversed the appeals court and held that supervisory prosecutors are shielded by absolute immunity for these kinds of office failures when they relate to a particular trial’s evidence. That ruling prevents many lawsuits seeking money from prosecutors over training, supervision, or informant-record systems and leaves other remedies or proceedings as the likely avenues for redress.