Consider the following hypothetical: You are awaiting trial for murder and are sentenced to two years in prison. You are facing the death penalty. You had cancer that relapsed without adequate treatment while incarcerated. It turns out that you were charged based on false witness statements and the local prosecutor allegedly destroyed the evidence to cover it up.
Now imagine prosecuting that prosecutor, only to be told that you have no recourse because these government employees are entitled to absolute immunity.
That’s the context for Justice Sonia Sotomayor’s opinion Tuesday that the Supreme Court may need to reassess the scope of the legal doctrine of absolute immunity from prosecution that blocks victims of alleged prosecutorial misconduct. Obtain the right of recourse. In most cases.
The case centers on Nikki Miller, a Kentucky man who was embroiled in a bizarre murder plot by a woman named Natasha Martin after the government offered her a deal to avoid prison. . The main problem: She almost immediately sought to retract the confession. Law enforcement will not accept this. So she testified before the grand jury and then tried to give up, writing In a letter to another man from prison, she suggested her comments were in response to “coercive interrogation tactics, threats and undisclosed promises of consideration”.
When Miller’s defense team heard about the letters, they tried to obtain them. Martin reportedly asked Assistant U.S. Attorney Keith Craycraft how she should comply with the order, and he allegedly responded that she should destroy the letters. She agreed.
The state eventually dropped charges against Miller. However, the two years in prison took a toll on him, according to his criminal defense attorney. explain His cancer was in remission, but came back after the state locked him up because he couldn’t get medication.
After his release, he sued Craycraft; the district court concluded that he was entitled to absolute immunity. The United States Court of Appeals for the Sixth Circuit famous Craycraft’s alleged misconduct is “difficult to justify and does not appear to be befitting of an officer charged with enforcing the criminal law”. This Court then also confirmed the grant of absolute immunity, which is a testament to the doctrine’s green light for such actions with its comprehensive precautions.
Miller has now died and his estate continues litigation on his behalf.
“Craycraft’s alleged misconduct in advising witnesses to destroy evidence to thwart a court order is shocking,” Write Sotomayor. “If this is what absolute immunity from prosecution protects, the courts may need to step in to ensure that the principle does not exceed its ‘reasonably prudent’ boundaries.
She also noted that “it is difficult to see how the conduct alleged here, including the destruction of evidence to thwart a court order…, is ‘so closely related to the judicial phase of a criminal proceeding.'”
The latter sentence comes from Imbler v. Paheitmann (1976), the Supreme Court’s precedent for declaring the doctrine of absolute immunity from prosecution. A court has ruled that a man who spent years in prison cannot sue a prosecutor who allegedly withheld evidence that ultimately exonerated him.
Plaintiffs may find a rare exception to absolute immunity if they can prove that prosecutors committed malfeasance outside the scope of their prosecutorial duties. This is a difficult task. Louisiana woman Priscilla Lefebure sues local prosecutor Samuel C. D’Aquilla for undermining her investigation into judicial system colleague Barre The rape case of Barrett Boeker.
D’Aquila, as I am wrote January 2023 issue reason“,” declined to provide the results of a medical examination, which found bruising, redness and irritation on Lefebvre’s legs, arms and cervix. difference in . “It’s uncomfortable to do this.”
Judge Shelly D. Dick of the U.S. District Court for the Middle District of Louisiana evaluated Lefebure’s lawsuit Summarize Some of D’Aquila’s actions fell within the scope of prosecutorial functions. But his “alleged conduct, which includes failing to request, obtain and examine a rape kit; taking notes on a police report; and failing to interview the complainant prior to a grand jury hearing,” she wrote, “is subject to absolute immunity. “investigative functions” does not apply. ” The 5th U.S. Circuit Court of Appeals later overturned that decision, ruling that Lefebvre was ineligible.
Sotomayor noted today that there are other ways to punish prosecutors for corruption because they “may still face criminal liability or ‘professional discipline'”. “However, these safeguards are only effective if used.”
This is an important warning. A central part of the Court’s argument for absolute immunity is the professional consequences prosecutors face for misconduct. But just as plaintiffs rarely clear the former hurdle, so does the latter option rarely exercise.
