Facts of the Case

Thomas Lee Goldstein was released on habeas corpus from a California prison in 2004 after serving twenty-four years of a murder sentence. Goldstein then brought suit against the prosecutor and chief deputy from his trial alleging that he had been wrongly convicted. Goldstein argued that he had been prejudiced by the testimony of a jailhouse informant claiming to have heard Goldstein confess to the murder. The informant had stated that he had never, either before or during the trial, received benefits for cooperating with the government; in fact, the informant had worked with the government in the past and was getting reduced sentences in exchange for his testimony. Goldstein's claim alleged that the prosecutor and deputy had failed to fulfill their obligation to ensure that information regarding jailhouse informants was adequately shared among prosecutors. In response, the prosecutors argued that their actions during the trial were immune from suit. The district court held that the actions were administrative rather than prosecutorial and were therefore not subject to immunity. The U.S. Court of Appeals for the Ninth Circuit agreed, finding that the prosecutor had failed to show the necessary close association with the judicial phase of the trial in order to invoke immunity.

Question

In a suit brought by a plaintiff alleging that he was wrongfully convicted of murder, are federal prosecutors entitled to absolute immunity against charges that they failed to satisfactorily share information regarding the testimony of a jailhouse informant during the course of the trial?

Conclusion

None