Knowlton v. Shaw
2013 U.S. App. LEXIS 293
| 1st Cir. | 2013Background
- Investigation by Maine Bureau of Insurance and AG into Bankers Life's marketing and sales practices targeting elderly.
- Shaw Griswold and Black negotiated to resolve claims with consent agreements, avoiding further proceedings against Bankers Life and Knowlton.
- Knowlton, Bangor branch manager, admitted violations at a January 2005 consent agreement with 60‑day license suspension and probation.
- Bankers Life subsequently entered a consent agreement terminating Knowlton and other Bangor/South Portland branch managers.
- Knowlton sued Shaw, Griswold, and Black in individual capacities under §1983 and §1985(2) seeking due process and conspiracy relief.
- District court dismissed the claims, holding absolute immunity for the state officials and rejecting §1985(2) and judicial estoppel arguments; Knowlton appeals.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether state officials have absolute immunity for §1983 claim. | Knowlton argues actions were administrative/investigative, not prosecutorial. | Officials acted as state's advocates prosecuting enforcement; entitled to absolute immunity. | Yes; actions were prosecutorial and shielded by absolute immunity. |
| Judicial estoppel applicability to immunity defense. | State officials should be estopped based on prior Maine Supreme Judicial Court representations. | No clear inconsistency or reliance; not same parties; no abuse of discretion shown. | No judicial estoppel; district court did not err. |
| Plausibility of §1985(2) conspiracy claim. | State officials conspired to deprive Knowlton of rights to his job with discriminatory intent. | Complaint lacks class-based invidiously discriminatory animus. | Dismissed; no plausible §1985(2) claim. |
| Whether absolute immunity precludes addressing due process merits. | Immunity shields only some actions; merits left undecided if immunity does not apply. | Absolute immunity bars §1983 claim entirely. | Court affirms immunity ruling; merits not reached. |
Key Cases Cited
- Butz v. Economou, 438 U.S. 478 (1978) (functional, prosecutorial-like immunity for administrative actions depends on nature of function)
- Burns v. Reed, 500 U.S. 478 (1991) (prosecutor's absolute immunity for judicial-process-associated acts; not all investigative actions)
- Buckley v. Fitzsimmons, 509 U.S. 259 (1993) (absolute immunity limited to prosecutorial functions; investigative acts may be only qualified)
- Imbler v. Pachtman, 424 U.S. 409 (1976) (prosecutorial function intimately associated with judicial process; basis for absolute immunity)
- Wang v. New Hampshire Bd. of Registration in Med., 55 F.3d 698 (1st Cir. 1995) (disciplinary proceedings; discretionary immunity analysis context)
- Harrington v. Almy, 977 F.2d 37 (1st Cir. 1992) (availability of safeguards not a precondition for absolute immunity)
- Romano v. Bible, 169 F.3d 1182 (9th Cir. 1999) (settlement negotiations may be within prosecutorial-like immunity)
- Buckley v. Buckley, 679 F. App’x (n/a) ((example placeholder to reflect related discussions))
- Gagliardi v. Sullivan, 513 F.3d 301 (1st Cir. 2008) (treating well-pleaded facts as true on Rule 12(b)(6) review)