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Kalina v. Fletcher

522 U.S. 118 (1997)

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Kalina v. Fletcher

United States Supreme Court
522 U.S. 118 (1997)

  • Written by Whitney Kamerzel , JD

Facts

Lynne Kalina (defendant), a prosecutor, initiated a criminal action against Rodney Fletcher (plaintiff) for the theft of school computer equipment. Kalina filed a motion for an arrest warrant and a sworn affidavit that certified the truth of the statements in support of the arrest warrant. Kalina filed the affidavit because Washington law required a signed affidavit establishing the grounds for an arrest warrant. The affidavit stated that Fletcher’s fingerprints were found at the school and that Fletcher did not have permission to be on the school’s property. The affidavit also stated that a witness identified Fletcher from a photo and stated that Fletcher inquired about selling the school’s equipment. Although these facts within the affidavit were false, the trial court declared that probable cause existed to issue an arrest warrant. Fletcher spent a day in jail, but Kalina later dropped the charges against Fletcher. Fletcher sued Kalina in federal district court under 42 U.S.C. § 1983 for making false statements within the affidavit. Kalina filed a motion to dismiss, arguing absolute prosecutorial immunity barred the suit. The district court dismissed Kalina’s motion, and the court of appeals affirmed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

Concurrence (Scalia, J.)

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