STANDING:
The district court below viewed the Rylands' claim as a suit by citizens to compel state prosecutors to initiate a criminal action against an alleged murderer.
On appeal, the Fifth Circuit found the district court had failed to entertain the legal theory upon which the Rylands based their case, that agents of the state intentionally engaged in conduct that interfered with their exercise of their constitutionally protected right to institute a wrongful death suit in the Louisiana courts. In other words, a denial of access to the courts.
The Circuit Court found the Ryland's had standing, because a summary judgment rendered as a result of a failure to entertain a valid legal theory is reversible error..., citing
Trevino v. Celanese Corp., 701 F.2d 397(5th Cir.1983)
The court then provided a thorough analysis of historic case law establishing denial of access to the courts as a deprivation of one of the most fundamental of Constitutional rights.
ABSOLUTE IMMUNITY:
The district court applied
Imbler v. Pachtman, 424 U.S. 409, and held that the defendants were shielded by absolute immunity because their actions were taken in their role as prosecutors. On this appeal, the Circuit Court disagreed.
The court noted that
Imbler left open the question whether this immunity extends to actions in which the prosecutor acts as an investigator or administrator, rather than as an advocate.
And cited the logic applied in
Bell v. City of Milwaukee, 514 F.Supp. 1363, 1372 (E.D.Wis.1981), [
Affirmed by Bell v. City of Milwaukee, 746 F.2d 1205 (7th Cir. 1984)]to support the finding that "the alleged actions of the defendants in falsifying the death certificate and in covering up the murder for a period of eleven months, if proven, were actions performed outside their role as prosecutors. Because... characterizing these actions as akin to those traditionally undertaken by officers of the court (which would entitle them to assert absolute immunity) would make a mockery of the judicial system.
Subsequent cases citing Ryland...