## Facts

- Thomas Lee Goldstein was convicted of murder in California in 1980, relying in part on testimony from jailhouse informant Edward Fink.
- Goldstein later obtained federal habeas relief after alleging that prosecutors failed to disclose impeachment material showing Fink had received benefits for testimony in other cases.
- After Goldstein’s release, he filed a damages action under 42 U.S.C. § 1983.
- Goldstein sued supervisory prosecutors John Van de Kamp (former district attorney) and Curt Livesay (former chief deputy), not the line prosecutor who tried the case.
- Goldstein alleged the supervisors (1) failed to train and supervise prosecutors on Brady/Giglio disclosure of informant impeachment material and (2) failed to establish an office system to track informants’ testimony history and benefits.
- The district court denied a motion to dismiss based on absolute prosecutorial immunity, treating the allegations as administrative.
- The Ninth Circuit affirmed, and the Supreme Court granted review.

## Issues

1. Whether supervisory prosecutors are absolutely immune under § 1983 for alleged failures to train or supervise line prosecutors on Brady/Giglio disclosure duties.
2. Whether supervisory prosecutors are absolutely immune under § 1983 for alleged failures to create or maintain an informant-information system used to comply with Brady/Giglio obligations in criminal cases.

## Decision

- The Supreme Court reversed the Ninth Circuit and held the supervisory prosecutors were entitled to absolute immunity.
- Applying a functional test, the Court concluded the challenged training, supervision, and information-system decisions were directly connected to trial-related prosecutorial functions.
- The Court reasoned that Goldstein’s theory depended on an alleged trial error (nondisclosure in his prosecution), and the supervisory claims were effectively derivative of that trial-related conduct.
- The Court emphasized that allowing damages suits over such supervisory decisions would risk burdensome litigation and impair prosecutorial independence in decisions tied to prosecutions.

## Legal Principles

- Absolute prosecutorial immunity applies to functions “intimately associated with the judicial phase of the criminal process,” determined by the function performed rather than the official’s title.
- Supervisory decisions about training, supervision, and information-management can fall within absolute immunity when they are closely tied to prosecutorial obligations concerning evidence disclosure in specific prosecutions.
- A plaintiff may not avoid absolute immunity for trial-related prosecutorial conduct by recasting the claim as a challenge to office policies or supervisory management connected to Brady/Giglio compliance.
- Prosecutorial acts that are investigative or administrative and sufficiently removed from the judicial phase may receive only qualified immunity, but trial-connected supervisory functions remain protected.

## Conclusion

The Court held that supervisory prosecutors are absolutely immune from § 1983 damages claims alleging failures in training, supervision, and informant-record systems when those alleged failures are tied to trial-related Brady/Giglio disclosure decisions in a particular prosecution.


Van de Kamp v. Goldstein, 555 U.S. 335 (2009)