Coggins v. Buonora, 776 F.3d 108

Coggins alleged that Nassau County officers falsified and omitted material facts in reports, lied to the DA and grand jury, and conspired to maliciously prosecute him.
Buonora testified before the grand jury; Coggins alleges the testimony was perjurious and connected to broader falsehoods in investigation and arrest papers.
Buonora pleaded guilty to perjury; Coggins’s charges were dropped after investigation by internal and district attorney divisions.
The district court granted partial immunity to Buonora—absolute immunity for grand jury testimony only—from some §1983 claims, and denied others; it also noted Rehberg’s impact on absolute immunity for grand jury witnesses.
Coggins’s TAC alleged non-grand-jury §1983 misconduct by Buonora and Vara, including falsified reports and conspiratorial conduct, independent of grand jury testimony.
On appeal, the Second Circuit affirmed to the extent of denying absolute and qualified immunity for non-grand-jury §1983 claims, and dismissed the rest for lack of pendent jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Buonora has absolute immunity for §1983 claims tied to grand jury testimony	Coggins argues immunity should extend to all related conduct.	Buonora contends Rehberg allows absolute immunity for grand jury testimony and related preparatory activity.	No; immunity does not extend to non-grand-jury misconduct.
Whether TAC’s non-grand-jury §1983 claims survive immunity	Claims exist independently of grand jury testimony and are actionable.	Some conduct is protected by absolute immunity if tethered to grand jury testimony.	Yes; non-grand-jury conduct survives absolute immunity and supports §1983 claims.
Whether Buonora is entitled to qualified immunity on §1983 claims	The alleged falsification and conspiracy violate clearly established law.	Qualified immunity should shield if reasonable belief no violation occurred.	Not entitled at this stage; alleged conduct violates clearly established law and is not objectively reasonable.
Whether the court should exercise pendent jurisdiction over remaining issues	Interests in full appellate review of immunity rulings.	Issues are not inextricably intertwined with core immunity questions.	Declined; dismissed balance of appeal for lack of pendant jurisdiction.

Rehberg v. Paulk, 132 S. Ct. 1497 (U.S. 2012) (grand jury witnesses have absolute immunity for §1983 claims based on testimony)
Pierson v. Ray, 386 U.S. 547 (U.S. 1967) (immunity principles in civil rights actions; scope of absolute immunity)
Marshall v. Randall, 719 F.3d 113 (2d Cir. 2013) (grand jury impeachment use; testimony may be used without violating Rehberg)
Transalt. Shiffahrtskontor GmbH v. Shanghai Foreign Trade Corp., 204 F.3d 384 (2d Cir. 2000) (premium on operative complaint; standards for testing pleading adequacy on appeal)