Randle v. Bell

Background

Ramello Randle, an inmate in the Contra Costa County Jail proceeding without an attorney, filed a civil-rights complaint under 42 U.S.C. § 1983 against the Contra Costa County District Attorney’s Office and three deputy district attorneys involved in his prosecution on murder charges in Contra Costa County Superior Court.

Randle alleged that, before his criminal trial, he filed two requests for disclosure of evidence that could clear him or be used to challenge the credibility of prosecution witnesses. He alleged that the defendants did not disclose that the witnesses were under investigation by the Federal Bureau of Investigation for perjury, which he said resulted in a mistrial. The opinion states that Randle was later retried and convicted of first-degree murder.

Randle listed claims including mental abuse, denial of a fair trial, public defamation, pain and suffering, cruel and unusual punishment, alleged violations of California Penal Code section 141(c), and racial discrimination. He sought money damages.

Screening standard

Because Randle was a prisoner suing governmental entities and employees, the court screened the complaint under 28 U.S.C. § 1915A. The court was required to identify claims that could proceed or dismiss claims that were frivolous, malicious, failed to state a claim for relief, or sought money from an immune defendant. The court also applied the rule that a complaint must provide enough factual information to make the requested relief plausible, rather than relying only on labels or conclusions.

Court’s analysis

The court treated Randle’s damages claim based on the alleged failure to disclose evidence as a claim that could not be judicially determined because of prosecutorial immunity. Prosecutors have absolute immunity from liability under § 1983 for conduct performed while pursuing a criminal prosecution as advocates for the government and closely connected to the judicial phase of the case.

The court explained that a prosecutor’s failure to disclose potentially favorable evidence before trial, during trial, or after conviction may violate due process, but that the prosecutor remains absolutely immune from a civil damages suit for performing that prosecutorial function. The court therefore held that the defendants were absolutely immune from Randle’s damages claim based on the alleged failure to disclose evidence.

Disposition

The complaint was dismissed for failure to state a claim capable of judicial review and determination. The dismissal was without leave to amend and with prejudice. Randle’s motion to issue subpoenas for complaints or criminal cases involving the defendants was denied. The Clerk was directed to enter judgment and close the file.