Aguilera v. Wright County
2014 U.S. Dist. LEXIS 141602
N.D. Iowa2014Background
- Plaintiff Jose Aguilera was convicted in 1996 of second-degree murder; Iowa Supreme Court later vacated the conviction based on a Brady violation and ordered a new proceeding. Aguilera had served 14 years before the conviction was set aside.
- Wright County prosecutors (Poppen, TeKippe, Simonson) handled the 1996 prosecution and later the 2012 re-prosecution (Simonson filed substitute charging papers); DCI agents conducted investigations (state defendants).
- The Iowa Supreme Court found the DCI investigative file was not disclosed until 2006 and held a Brady violation occurred, but did not identify precisely who failed to disclose the file.
- Aguilera sued county prosecutors and Wright County under § 1983 and state tort law, alleging fabrication/concealment of evidence, malicious prosecution, false imprisonment, intentional infliction of emotional distress, conspiracy, Brady/Giglio violations, and municipal liability (policy/custom/indemnity).
- County Defendants moved for summary judgment asserting absolute prosecutorial immunity, multiple alternative defenses (Monell/respondeat superior inapplicable, Fifth Amendment inapplicable to states, lack of favorable termination for 2012 claims, etc.).
- District court held that the individual prosecutors and Wright County are entitled to absolute prosecutorial immunity for the claims arising from charging and post-charging conduct and granted summary judgment to the County Defendants; other asserted claims (Monell, indemnity, equal protection, substantive due process, 2012 claims lacking favorable termination) also failed as a matter of law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether prosecutors have immunity for alleged Brady violations and other misconduct in initiating/pursuing prosecution | Aguilera contends Brady violation and intentional misconduct should allow damages; Poppen acted administratively in withholding files; Simonson acted as a complaining witness in 2012 | Prosecutorial acts in charging/post-charging phases are absolutely immune; signing charging papers does not make Simonson a complaining witness; immunity not defeated by malice | Absolute prosecutorial immunity bars damages claims for the alleged misconduct; summary judgment for County Defendants on these claims |
| Whether Wright County is liable under § 1983 (Monell or respondeat superior) | Wright County liable based on Poppen’s office policy of withholding investigative files and indemnity under Iowa law | Municipality cannot be liable on respondeat superior; no showing of official policy, custom, or deliberate indifference causing constitutional injury; § 670.8 only creates indemnity, not independent county liability | No Monell or respondeat superior liability; summary judgment for Wright County; indemnity statute does not create independent liability |
| Whether claims based on the 2012 re-prosecution are viable without a favorable termination | Aguilera argues he lacks other remedies and should recover despite not being fully exonerated | Federal law requires favorable termination for malicious prosecution/related claims stemming from later prosecution | Claims arising from 2012 re-prosecution fail for lack of favorable termination; summary judgment granted |
| Whether substantive due process or equal protection claims survive despite immunity and other defects | Aguilera asserts conduct shocks the conscience and reflects racial animus | Equal protection claim lacks required comparative evidence; substantive due process claims are duplicative of prosecutorial claims and covered by immunity | Equal protection and substantive due process claims fail; equal protection conceded by plaintiff; substantive due process barred by immunity/duplicative theory |
Key Cases Cited
- Imbler v. Pachtman, 424 U.S. 409 (recognizing absolute prosecutorial immunity for initiating and pursuing prosecutions)
- Buckley v. Fitzsimmons, 509 U.S. 259 (distinguishing prosecutorial advocacy from investigative/administrative functions for immunity analysis)
- Kalina v. Fletcher, 522 U.S. 118 (distinguishing sworn affidavits supporting warrants from unsworn charging statements for immunity purposes)
- Monell v. Department of Social Services, 436 U.S. 658 (municipal liability under § 1983 requires official policy, custom, or failure to train)
- Saterdalen v. Spencer, 725 F.3d 838 (Eighth Circuit applying absolute immunity to prosecutorial acts initiating prosecution)