James Rieves v. Town of Smyrna, Tenn.

Summary

The Sixth Circuit held that prosecutors are not entitled to absolute immunity for directing law enforcement investigations and providing legal advice during the investigative phase, before probable cause exists or judicial proceedings begin. The court also denied qualified immunity to the prosecutors and the sheriff on Fourth Amendment false arrest claims because it was objectively unreasonable to rely on inconclusive TBI lab reports that could not determine whether CBD products were illegal under Tennessee law. However, the sheriff was granted qualified immunity on the equal protection selective-enforcement claim because the complaint failed to allege his personal involvement in the decision to target small businesses over larger retailers. The case clarifies that prosecutors acting as investigators rather than advocates, and officials who ignore exculpatory evidence, are not shielded by immunity.

Questions Presented

1. Whether Jones and Zimmerman are entitled to absolute prosecutorial immunity or qualified immunity for their actions during the investigation.
2. Whether Fitzhugh is entitled to quasi-judicial absolute immunity or qualified immunity for his actions related to the investigation and arrests.
3. Whether Fitzhugh is entitled to qualified immunity on the plaintiffs' equal protection claim.