Elaine Royse v. Reed Wilbers
669 F. App'x 296
| 6th Cir. | 2016Background
- Elaine Royse, a Florida resident, was charged in Kentucky state court with knowingly abusing or neglecting an adult based on a 2007 incident while she worked as an LPN; the state charge was later dismissed because an investigator, Reed Wilbers, allegedly presented false grand-jury testimony.
- Royse sued Wilbers in Kentucky state court for malicious prosecution (federal and state claims), seeking monetary damages.
- Wilbers removed the case to federal court and moved to dismiss under Fed. R. Civ. P. 12(b)(6), asserting absolute immunity for his grand-jury testimony.
- The district court granted the motion and dismissed Royse’s complaint for failure to state a claim, concluding the complaint rested solely on grand-jury testimony, which is absolutely immune.
- Royse appealed, relying on Webb v. United States to argue that being the sole grand-jury witness could show participation in the decision to prosecute, but the panel found Webb inapposite.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a malicious-prosecution claim based solely on grand-jury testimony can proceed | Royse: Webb suggests sole-witness grand-jury testimony can show participation in prosecution decision | Wilbers: Grand-jury testimony is absolutely immune; no actionable conduct pleaded | Court: Dismiss—absolute immunity applies to claims based only on grand-jury testimony |
| Whether Webb undermines Rehberg and defeats absolute immunity | Royse: Webb indicates sole-witness status can show prosecutorial decision-making | Wilbers: Webb addressed qualified immunity, not absolute immunity; Rehberg controls | Court: Webb is inapplicable; Rehberg controls absolute-immunity analysis |
Key Cases Cited
- Ashcroft v. Iqbal, 556 U.S. 662 (establishes pleading standard for drawing inferences of liability)
- Rehberg v. Paulk, 566 U.S. 356 (absolute immunity protects grand-jury testimony)
- Webb v. United States, 789 F.3d 647 (6th Cir. 2015) (addressed qualified immunity; factual participation beyond testimony relevant)
- Coggins v. Buonaora, 776 F.3d 108 (2d Cir. 2015) (applies Rehberg to bar claims based solely on grand-jury testimony)