Sample v. City of Woodbury, No. 15-3213 (8th Cir. 2016)
Annotate this CasePlaintiff filed suit under 42 U.S.C. 1983, alleging that the City's failure to develop a conflict-of-interest policy led to a violation of his constitutional rights when prosecutors (the Attorneys) filed a criminal complaint against him while simultaneously representing the victim of his alleged crime in separate civil actions. The district court granted the City’s and the Attorneys’ separate motions to dismiss under Federal Rule of Civil Procedure 12(b)(6). The district court dismissed a remaining state law claim under Minnesota’s doctrine of statutory discretionary immunity. The court affirmed the district court's dismissal of the complaint against the Attorneys based on absolute prosecutorial immunity where the development of a conflicts policy and the determination as to what constitutes a conflict of interest would necessarily require legal knowledge and the exercise of related discretion, features to which the doctrine of absolute immunity applies; reversed the district court's finding that the City is absolutely immune from suit on plaintiff's section 1983 claim where municipalities do not enjoy absolute immunity from suit under section 1983; and reversed as to the supplemental state law claims based on the same reasoning.
Court Description: Perry, Author, with Murphy and Shepherd, Circuit Judges] Civil case - Civil rights. The attorneys who filed criminal charges against plaintiff on behalf of the City were entitled to absolute immunity for the act even if they had a conflict of interest at the time they filed the charges; the district court did not err in finding absolute immunity bared plaintiff's Section 1983 and negligence claims to the extent they alleged the attorneys wrongfully failed to develop a conflicts policy; absolute immunity does not bar plaintiff's claims against the City and the district court erred in finding the City was absolutely immune from suit on the Section 1983 and supplemental state law claims; those claims are remanded for further proceedings.
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