Gosier v. Oneida County District Attorney's Office, 6:23-cv-01118

Pro se plaintiff Willie Gosier filed a 42 U.S.C. § 1983 suit alleging he was framed for state-law crimes by the Oneida County District Attorney’s Office, the District Attorney, and several Assistant DAs.
Gosier sought leave to proceed in forma pauperis; the IFP application was eventually granted.
Magistrate Judge Dancks issued a Report & Recommendation (R&R) recommending dismissal without leave to amend, concluding defendants were protected by prosecutorial and related immunities and that the alleged conduct was integral to the prosecutorial phase.
Gosier objected, conceding official-capacity claims may be barred but arguing he should be allowed to press individual-capacity claims and offering reduced damages or equitable relief (e.g., expungement).
District Judge Hurd reviewed the objections de novo, accepted the R&R, and dismissed the complaint without leave to amend, emphasizing the broad scope of prosecutorial immunity and noting other remedies (criminal or disciplinary) exist.
The court also held that the equitable relief Gosier sought would implicate abstention principles because it would require intervention in an ongoing state criminal proceeding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants are immune from § 1983 liability for the alleged conduct	Gosier: individual-capacity claims may proceed despite official-capacity bars	Prosecutors: entitled to broad prosecutorial immunity for acts tied to prosecution	Court: Prosecutorial immunity bars the claims; dismissal without leave to amend
Whether Gosier may obtain equitable relief (e.g., record expungement) via § 1983	Gosier: would accept equitable relief or reduced damages instead of full damages	Defendants: such relief would require federal intervention in state criminal matters; abstention applies	Court: Equitable relief would be barred by abstention principles; not available here
Whether leave to amend should be granted	Gosier: implied request to pursue individual-capacity claims or narrow relief	Defendants: amendment would be futile given immunity and abstention barriers	Court: Leave to amend denied as futile

Flagler v. Trainor, 663 F.3d 543 (2d Cir. 2011) (prosecutorial immunity covers many actions intimately associated with the judicial phase)
Anilao v. Spota, 27 F.4th 855 (2d Cir. 2022) (courts rely on non-§ 1983 mechanisms to deter prosecutorial wrongdoing when immunity applies)
Sprint Commc’ns, Inc. v. Jacobs, 571 U.S. 69 (2013) (abstention principles preclude federal intervention that would interfere with ongoing state-court proceedings)