Brown v. Jenkins

Background

Andre Vincent Brown alleged that district attorneys and public defenders violated his constitutional rights during his state criminal proceedings. He brought the action under 42 U.S.C. § 1983, a federal law that allows claims against people who, while acting under state authority, violate rights protected by the Constitution or federal law.

Screening standard

The court reviewed the complaint under 28 U.S.C. § 1915A, which requires federal courts to screen lawsuits by prisoners seeking relief from governmental entities or their officers or employees. The court must identify claims that are frivolous, malicious, fail to state a claim, or seek relief from an immune defendant. The court also stated that a § 1983 claim requires an alleged violation of a federal right by a person acting under color of state law.

Claims against the district attorneys

Brown alleged that Brooke Jenkins and Diego Lopez were district attorneys who violated his constitutional rights. The court held that state prosecutors have absolute immunity from damages claims under § 1983 for conduct undertaken while pursuing a criminal prosecution as advocates for the state and closely connected to the judicial phase of the criminal process. The court therefore dismissed Brown’s claims against Jenkins and Lopez.

Claims against the public defenders

Brown alleged that Manohar Raju and Stephen Olmo were public defenders who violated his constitutional rights. The court held that a public defender does not act under color of state law when performing traditional functions as a defense lawyer. The court therefore dismissed Brown’s claims against Raju and Olmo.

Disposition

The court dismissed the federal civil-rights action. It directed the Clerk to enter judgment in favor of the defendants and close the file. The opinion does not state that the dismissal was with or without prejudice.