Price v. Montgomery County

Background

Nickie Miller is a man who was charged with murder after a witness gave a confession that later proved false. The witness later recanted and wrote jailhouse letters to her husband saying her confession was coerced. A court ordered the letters turned over to Miller’s defense, but the lead prosecutor allegedly encouraged the witness to destroy them. Miller spent two years in jail before the State dropped the charges, and he sued the prosecutor and others under a federal civil-rights law claiming malicious prosecution, fabrication and destruction of evidence, due-process violations, and conspiracy.

Reasoning

The core question was whether a prosecutor can be sued under this civil-rights law when, as alleged here, the prosecutor knowingly destroyed exculpatory evidence and defied a court order. The Supreme Court declined to take the case and left the lower courts’ dismissal—based on absolute prosecutorial immunity—in place. Justice Sotomayor, writing about the denial, stressed that the denial should not be seen as approval of the alleged misconduct and warned that immunity has limits.

Real world impact

Because the Court refused review, the alleged victim has no civil remedy in this case and the immunity ruling stands for now. The statement notes that prosecutors may still face criminal charges or professional discipline, but those safeguards are rarely used. This decision is not a final ruling on whether such immunity should protect this conduct; similar cases could still reach the Court.

Dissents or concurrances

A lower-court judge described the prosecutor’s conduct as difficult to justify, and a concurrence discussed historical scholarship questioning the scope of current immunity doctrine.