Renenger v. State

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The Supreme Court affirmed the judgment of the district court granted the State’s motion to dismiss and Jefferson County’s motion for summary judgment as to Plaintiffs’ complaint against special deputy prosecutor Steven Shapiro, the State, and Jefferson County, holding that the district court properly concluded that Shapiro was entitled to absolute prosecutorial immunity and that this immunity was properly extended to both Jefferson County and the State. Plaintiffs brought this complaint seeking damages under 42 U.S.C. 1983, alleging violations of their child’s constitutional rights, a Dorwart claim, and a malicious prosecution claim. Plaintiffs also filed a negligence claim against Jefferson County. The district court granted the motion to dismiss brought by the State and Shapiro on the grounds of absolute prosecutorial immunity. The court then granted summary judgment for Jefferson County on the grounds that the public duty doctrine barred Plaintiffs’ claims. The Supreme Court affirmed, holding that the district court (1) correctly concluded that Shapiro was entitled to absolute prosecutorial immunity when he signed an affidavit establishing probable cause to file a petition initiating delinquency proceedings against Plaintiffs’ child; (2) properly extended this immunity to Jefferson County and the State; and (3) correctly concluded that the public duty doctrine prevented recovery against Jefferson County. View "Renenger v. State" on Justia Law