Narrative Opinion Summary
In this case, the Fallon County Attorney and a special prosecutor appealed the denial of their motion for summary judgment on the grounds of absolute and qualified immunity related to the prosecution of Russell Stinnett. The court affirmed parts of the denial and reversed others, granting Houtz absolute immunity for filing charges but not for allegedly false attestations during the investigation. Huntley was found immune for his role in the decision to file charges but not for investigative actions. The court found that Houtz and Huntley were entitled to qualified immunity unless it was demonstrated that they violated clearly established constitutional rights. The court upheld the denial of Houtz's qualified immunity regarding deliberate fabrication claims but reversed it concerning Fourth Amendment claims, finding no evidence of rights violations. Stinnett's claims of rights violations focused on alleged fabrications in charges rather than the investigation itself. The court also held that probable cause findings negated Fourth Amendment claims, leading to a partial reversal of previous rulings. Costs on appeal were not awarded, and the decision was deemed not suitable for publication or citation under Ninth Circuit Rule 36-3.
Legal Issues Addressed
Absolute Immunity for Prosecutorssubscribe to see similar legal issues
Application: Houtz is granted absolute immunity for his decision to file charges against Stinnett, while Huntley is immune for his role in the decision to file charges but not for investigative actions.
Reasoning: Houtz is not entitled to absolute immunity for allegedly falsely attesting to facts during the investigation of Russell Stinnett, but he is granted absolute immunity for his decision to file charges against Stinnett.
Fourth Amendment Claims and Absolute Immunitysubscribe to see similar legal issues
Application: Stinnett's Fourth Amendment claim fails as the court found Houtz and Huntley were immune from liability for filing charges, and Stinnett did not sufficiently show they engaged in unprotected conduct.
Reasoning: The court did not need to determine if this right was clearly established, as Stinnett failed to show that Houtz or Huntley engaged in unprotected conduct leading to the restrictions.
Judicial Deception and Fabrication of Evidencesubscribe to see similar legal issues
Application: Material omissions in affidavits can constitute deliberate fabrication of evidence, but Stinnett's allegations were deemed insufficient to prove such fabrication by Houtz or Huntley.
Reasoning: Material omissions in an affidavit may amount to deliberate fabrication of evidence, as noted in Devereaux, and could also be subject to a judicial deception theory under due process claims, as referenced in Galbraith v. County of Santa Clara.
Qualified Immunity in Civil Rights Violationssubscribe to see similar legal issues
Application: Houtz and Huntley are entitled to qualified immunity unless it is shown that they violated Stinnett's constitutional rights, which were clearly established.
Reasoning: Houtz and Huntley are entitled to qualified immunity unless their actions violated Stinnett's constitutional rights and those rights were clearly established.