Sines v. Hummel
6:20-cv-00432
| D. Or. | Sep 23, 2020Background
- Pro se plaintiff John Albert Sines was indicted in 2006 for sexual abuse, sodomy, and rape of his adopted children; convicted in 2009 and appealed through state courts.
- State appellate activity concluded with decisions through 2018 and a new trial scheduled for November 17, 2020.
- Sines filed a federal pro se complaint alleging prosecutors committed Brady violations, witness tampering/bribery, suppression of evidence, use of evidence from an illegal search, and other misconduct, and sought injunctive relief and dismissal of the state prosecution.
- Defendants (state prosecutors and the Oregon Attorney General’s Office) moved for summary judgment, asserting Rooker–Feldman jurisdictional bar, Eleventh Amendment sovereign immunity for the AG’s Office, and absolute prosecutorial immunity for individual prosecutors.
- The district court concluded Sines’s claims impermissibly collaterally attacked state-court judgments and granted summary judgment for defendants, dismissing the case with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Jurisdiction under Rooker–Feldman | Sines challenges prosecutorial conduct and seeks relief affecting state convictions and proceedings | Federal court lacks jurisdiction over federal suits that seek review/rejection of state-court judgments | Rooker–Feldman bars Sines’s claims; federal court lacks jurisdiction |
| Sovereign immunity (Eleventh Amendment) | Suits against the Oregon Attorney General’s Office are permissible | State did not waive immunity; §1983 does not permit suit against state agencies | AG’s Office immune and dismissed with prejudice |
| Prosecutorial immunity (absolute) | Prosecutors’ alleged suppression/tampering/etc. are actionable under §1983 | Prosecutors are absolutely immune for acts intimately associated with the judicial phase (e.g., evaluating/presenting evidence) | Individual prosecutors entitled to absolute immunity; dismissed with prejudice |
| Summary judgment standard / entitlement | Factual disputes or constitutional questions require trial | No genuine issue of material fact; legal doctrines (Rooker–Feldman, sovereign and prosecutorial immunity) dispose of case | Summary judgment granted for defendants; case dismissed with prejudice |
Key Cases Cited
- Exxon Mobil Corp. v. Saudi Basic Indus. Corp., 544 U.S. 280 (2005) (limits federal review of state-court judgments under Rooker–Feldman)
- Dist. of Columbia Court of Appeals v. Feldman, 460 U.S. 462 (1983) (establishes that federal courts cannot review final state-court decisions)
- Rooker v. Fidelity Trust Co., 263 U.S. 413 (1923) (origin of doctrine prohibiting federal collateral review of state judgments)
- Imbler v. Pachtman, 424 U.S. 409 (1976) (recognizes absolute prosecutorial immunity for conduct intimately associated with judicial phase)
- Buckley v. Fitzsimmons, 509 U.S. 259 (1993) (functional approach to official immunity focuses on nature of the function performed)
- Va. Office for Prot. & Advocacy v. Stewart, 563 U.S. 247 (2011) (discusses state sovereign immunity and waiver principles)
- Anderson v. Liberty Lobby, Inc., 477 U.S. 242 (1986) (standard for summary judgment and genuine issue of material fact)
- Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986) (nonmoving party must present specific facts showing a genuine issue for trial)