Mark Woodworth v. Kenneth Hulshof, 891 F.3d 1083

In 1990 two neighbors were shot; one died. Lyndel Robertson initially accused Brandon Thomure but later abandoned that theory. Investigation stalled until Lyndel hired private investigator Terry Deister, who focused on Mark Woodworth (then 16).
Deister gained influence over the investigation; prosecutors later found forensic evidence implicating Woodworth. Livingston County Prosecuting Attorney Doug Roberts disqualified himself; Judge Kenneth Lewis appointed the Missouri Attorney General’s Office and sent appointment materials (the “Lewis Letters”) to then‑Assistant AG Kenneth Hulshof.
The Lewis Letters and related materials contained impeachment/exculpatory information (e.g., Lyndel’s prior identification of Thomure) not disclosed to Woodworth at trial. Woodworth was convicted twice; convictions were later vacated after Missouri Supreme Court habeas proceedings found Brady violations and other irregularities.
After release, Woodworth sued under 42 U.S.C. § 1983, alleging Hulshof and Judge Lewis concealed exculpatory evidence and conspired to present false evidence. The district court granted summary judgment for both defendants on absolute immunity and related grounds.
The Eighth Circuit affirmed, holding Hulshof entitled to absolute prosecutorial immunity for actions linked to initiating and presenting the prosecution, and Judge Lewis entitled to absolute judicial immunity for acts taken in his judicial capacity.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Hulshof is liable for concealing Brady/exculpatory evidence and for conspiracy	Woodworth: Hulshof suppressed Lewis Letters and other exculpatory material and conspired (including via pre‑appointment communications) to present false evidence	Hulshof: acts were prosecutorial (initiation/presentation) and thus absolutely immune; plaintiff lacks evidence of pre‑appointment conspiracy	Held: Hulshof entitled to absolute prosecutorial immunity; summary judgment affirmed
Whether Judge Lewis is liable for concealing evidence and conspiring with prosecutor	Woodworth: Lewis acted nonjudicially (e.g., acted as a prosecutor, ex parte contacts, appointed foreman with conflicts) so no immunity	Lewis: alleged misconduct occurred in the exercise of judicial functions (appointing prosecutor, convening grand jury, presiding over juvenile certification), so absolute judicial immunity applies	Held: Judge Lewis entitled to absolute judicial immunity; summary judgment affirmed

Imbler v. Pachtman, 424 U.S. 409 (prosecutors absolutely immune for initiating/presenting prosecution)
Buckley v. Fitzsimmons, 509 U.S. 259 (functional approach to absolute immunity; distinguishes investigative vs. prosecutorial acts)
Burns v. Reed, 500 U.S. 478 (immunity for acts intimately associated with judicial phase)
Mireles v. Waco, 502 U.S. 9 (broad scope of judicial immunity despite allegations of bad faith)
Reasonover v. St. Louis Cty., 447 F.3d 569 (summary judgment standard; prosecutors immune for presentation and suppression of evidence)
Schottel v. Young, 687 F.3d 370 (judicial immunity exceptions and definition of judicial act)
Rowe v. City of Ft. Lauderdale, 279 F.3d 1271 (acts covered by absolute immunity cannot be used to infer non‑immune conspiracy)
Ashelman v. Pope, 793 F.2d 1072 (conspiracy allegations between judge and prosecutor insufficient to overcome judicial immunity)