Christopher Lee Card v. County of Alameda, et al.

Summary

The United States District Court for the Northern District of California dismissed Christopher Lee Card’s 42 U.S.C. § 1983 complaint seeking monetary and punitive damages against Alameda County and various prosecutors, public defenders, psychologists, and county counsel. The court held that the individual defendants were protected by absolute immunity or were not state actors, and that Card had not adequately alleged municipal liability against Alameda County. The dismissal was without leave to amend, and the court certified that an in forma pauperis appeal would not be taken in good faith.

Holdings

1. A prosecutor is absolutely immune from damages liability for conduct undertaken in the advocate's role in initiating and pursuing a criminal case; therefore, Card's claims against Deputy District Attorney Ikuma were dismissed.
2. A public defender does not act under color of state law when performing a lawyer's traditional functions, including representation related to a client's mental competency; therefore, Card's § 1983 claims against the public defenders were dismissed.
3. Witnesses are absolutely immune from liability for testimony in state or federal court proceedings, including allegedly perjured testimony; therefore, Card's claims against the court-appointed psychologists were dismissed.
4. Absolute immunity extends to government officials performing prosecutorial or judicial functions, including analogous functions in administrative or adversarial proceedings; to the extent the deputy county counsels acted in a prosecutorial role, they were absolutely immune, and the claims against them were dismissed.
5. A local government cannot be held liable under § 1983 solely on a respondeat superior theory; because Card alleged no other basis for municipal liability, his claim against Alameda County was dismissed.
6. All claims for punitive and monetary damages were dismissed without leave to amend, and the court certified under 28 U.S.C. § 1915(a)(3) that an in forma pauperis appeal would not be taken in good faith.

Questions Presented

1. Whether the claims against the deputy district attorney were barred by absolute prosecutorial immunity.
2. Whether the claims against the public defenders stated a claim under 42 U.S.C. § 1983 when the public defenders were performing traditional functions of defense counsel.
3. Whether the claims against the court-appointed psychologists were barred by absolute witness immunity.
4. Whether the claims against the deputy county counsel were barred by absolute immunity for prosecutorial or quasi-judicial functions.
5. Whether the complaint stated a claim for municipal liability against Alameda County under § 1983.
6. Whether the court should dismiss the claims without leave to amend and certify that an in forma pauperis appeal would not be taken in good faith.

Disposition

dismissed