Kroemer v. Tantillo

Summary

Kroemer v. Tantillo (2d Cir. 2018) addresses Brady claims and prosecutorial immunity under § 1983. The Second Circuit affirmed dismissal of the plaintiff's § 1983 action alleging Brady violations against law enforcement officers, holding that the allegedly suppressed evidence was not material because it would not have changed the outcome of his state drug trial. The court further held that the defendant prosecutor was entitled to absolute immunity for conduct—including seeking an amended indictment and preparing a witness—falling within his role as an advocate. The court also affirmed denial of post‑judgment motions under Rules 59(e) and 60(b) as merely seeking to relitigate decided issues.

Holdings

1. The court agreed with the district court that Kroemer failed to adequately establish the materiality of the allegedly suppressed evidence, and therefore the claims were properly dismissed.
2. The district court correctly concluded that Tantillo is entitled to absolute immunity because his conduct in seeking an amended indictment and preparing a witness for trial falls within the prosecutor's role as advocate.
3. The district court did not abuse its discretion because Kroemer's motions merely sought to relitigate already-decided issues and did not demonstrate exceptional circumstances.

Questions Presented

1. Whether the district court erred in dismissing Brady claims against defendants Smith and Fischer for failure to state a claim.
2. Whether the district court erred in dismissing the fabrication of evidence claim against defendant Tantillo on absolute immunity grounds.
3. Whether the district court erred in denying Kroemer's post-judgment motions under Rules 59(e) and 60(b).

Disposition

affirmed