Scott v. Wagstaffe
- Richard Seeborg
- 3:25-cv-04217
- U.S. District Court · Northern District of California
- 2
In Scott v. Wagstaffe, Judge Seeborg dismissed Scott’s civil-rights action after finding prosecutors immune, and denied his request to proceed without paying fees.
Christopher D. Scott's federal civil-rights action was dismissed. The defendants received judgment in their favor. Scott's request to proceed without paying filing fees was denied, subject to possible reconsideration if he submits the required account statement.
What happened
In Scott v. Wagstaffe, Christopher D. Scott alleged that district attorneys violated his constitutional rights while prosecuting him. The court reviewed his civil-rights complaint under a law requiring early review of prisoner claims against government officials.
The court concluded that prosecutors are protected from lawsuits for conduct connected to pursuing a criminal prosecution as advocates for the state. It therefore dismissed the federal civil-rights action.
Judge Seeborg also denied Scott’s request to proceed without paying filing fees because he did not provide the required six-month prison trust-account statement. The court said it would reconsider that request if Scott submits the proper document, entered judgment for the defendants, and closed the case.
The detailed version
- Scott v. Wagstaffe · No. 3:25-cv-04217
- Richard Seeborg
- June 24, 2025
Background
Christopher D. Scott filed a complaint under 42 U.S.C. § 1983, a federal law allowing claims against people acting under state authority for violating federal constitutional or legal rights. He alleged that district attorneys violated his rights during their prosecution of him. The caption identifies Stephen M. Wagstaffe and other defendants; the discussion identifies District Attorney Steven M. Wagstaffe and Deputy District Attorney Ivan J. Nightengale.
Screening and immunity
The court reviewed the complaint under 28 U.S.C. § 1915A, which requires early screening of a prisoner's claims against governmental entities or officials. At screening, the court must dismiss claims that are frivolous, fail to state a claim, or seek money from a defendant immune from that relief. The court also noted that pleadings filed without a lawyer must be read liberally.
The court held that a state prosecuting attorney has absolute immunity from damages liability under § 1983 for conduct undertaken while pursuing a criminal prosecution as an advocate for the state and closely connected to the judicial phase of the criminal process. Applying that rule, the court dismissed the federal civil-rights action.
Other ruling and disposition
The court denied Scott's motion to proceed without paying filing fees because he had not submitted a prison trust-account statement showing transactions for the preceding six months. The court stated that it would reconsider the motion if he submitted the proper document. It directed the Clerk to terminate all pending motions, enter judgment in favor of the defendants, and close the file. The opinion does not state that the dismissal was with or without prejudice.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.