Background
Lakeria Montgomery, a corrections officer, sued Assistant District Attorney Coy Morgan and the Mobile County Metro Jail. Montgomery alleged that Morgan falsely accused her of smuggling contraband cellphones to her brother, an inmate, to influence a criminal case he was prosecuting. She claimed this led to her termination and sought damages for emotional distress and defamation. The district court dismissed the complaint, granting the prosecutor’s motion to dismiss based on absolute prosecutorial immunity and other defenses.
The court’s reasoning
The Eleventh Circuit reviewed the dismissal de novo. The court noted that the district court granted the motion to dismiss based on reasons stated at a hearing, but Montgomery failed to include the hearing transcript in the appellate record. This omission prevented the appellate court from reviewing whether the district court erred in its factual findings. Furthermore, the court analyzed the merits of the immunity claim. The court explained that prosecutors are absolutely immune from liability under Section nineteen hundred and eighty-three for activities intimately associated with the judicial phase of the criminal process. The court found that Morgan’s actions, including using evidence to prosecute a case, were undertaken in his role as an advocate for the state. The court concluded that even if the prosecutor’s acts were wrongful or malicious, they were protected by absolute immunity.
What it means going forward
This decision reinforces the broad scope of absolute prosecutorial immunity in the Eleventh Circuit, shielding prosecutors from civil suits even when their conduct is alleged to be malicious or wrongful, provided the acts are functionally related to the judicial process.
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