Term: 2008
Docket: 07-854
John Van De Kamp, Et Al. v. Thomas Lee Goldstein
- Pro
07-854 VAN DE KAMP V. GOLDSTEIN DECISION BELOW:481 F3d 1170 CERT. GRANTED 4/14/2008 QUESTIONS PRESENTED: 1) Where absolute immunity shields an individual prosecutor’s decisions regarding the disclosure of informant information in compliance with Brady v. Maryland, 373 U.S. 83 (1963) and Giglio v. United States, 405 U.S. 150 (1972) made in the course of preparing for the initiation of judicial proceedings or trial in any individual prosecution, may a plaintiff circumvent that immunity by suing one or more supervising prosecutors for purportedly improperly training, supervising, or setting policy with regard to the disclosure of such informant information for all cases prosecuted by his or her agency? 2) Are the decisions of a supervising prosecutor as chief advocate in directing policy concerning, and overseeing training and supervision of, individual prosecutors’ compliance with Brady v. Maryland, 373 U.S. 83 (1963) and Giglio v. United States, 405 U.S. 150 (1972) in the course of preparing for the initiation of judicial proceedings or trial for all cases prosecuted by his or her agency, actions which are “intimately associated with the judicial phase of the criminal process” and hence shielded from liability under Imbler v. Pachtman, 424 U.S. 409, 430 (1976)? LOWER COURT CASE NUMBER: 06-55537
In the case of John Van de Kamp et al. v. Thomas Lee Goldstein, 2008, the U.S Supreme Court ruled in favor of prosecutors who were accused of withholding evidence that could have exonerated a man wrongfully convicted for murder. Thomas Lee Goldstein had spent 24 years in prison before his conviction was overturned due to prosecutorial misconduct and false testimony from a jailhouse informant. He then sued former Los Angeles County District Attorney John Van de Kamp and his chief deputy, Curt Livesay, alleging they failed to properly train prosecutors or set up an information system about informants which led to violation of his constitutional rights. However, the court held by a vote of 5-4 that these officials were immune from such lawsuits because their actions related directly to how trials are conducted - an area where absolute immunity has traditionally been upheld.
In the dissenting opinion for John Van De Kamp, et al. v. Thomas Lee Goldstein, Justice Stevens argued that prosecutors should not be granted absolute immunity from lawsuits when they fail to properly train their subordinates or establish necessary information-sharing systems within their offices. He contended that such failures could lead to wrongful convictions and thus violate an individual's constitutional rights. In this case, he believed that the Los Angeles County District Attorney’s Office had failed in its duty by not ensuring a system was in place to share impeachment evidence about jailhouse informants among its prosecutors - leading to Mr. Goldstein spending 24 years in prison for a murder he did not commit based on false testimony from an unreliable informant.
