Timothy Rouse v. Terry Powlde, 478 F. App'x 945

Rouse, a pro se §1983 plaintiff, sued Fulton County officials including Stacy, alleging Stacy ordered jailers to assault him to coerce a guilty plea while he awaited trial.
Stacy moved to dismiss; the district court dismissed official-capacity claims under the Eleventh Amendment and dismissed the denial-of-fair-trial claim under Heck, while allowing the excessive-force claim to proceed.
Allegations describe a late-night beating by jailers after a court hearing, purportedly at Stacy’s direction, followed by a guilty plea on the first day of trial.
Rouse sought to withdraw his plea, citing probation-restrictions consequences; Kentucky appellate decisions are referenced to context the plea process.
The Sixth Circuit affirmed the district court, concluding Stacy was not entitled to prosecutorial immunity because ordering a beating was not within the scope of prosecutorial authority, and thus not prosecutorial conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Stacy is entitled to prosecutorial immunity	Rouse argues immunity shields Stacy for plea-bargaining conduct.	Stacy argues pleading negotiations are absolutely immune as prosecutorial function.	No absolute immunity for the beating; not within prosecutorial scope.
Whether the alleged assault falls within the therapeutic scope of plea bargaining	Beating was used to induce a plea, aiding the plea process.	Plea bargaining is a prosecutorial function warranting immunity.	Beating outside legitimate prosecutorial authority; not protected.
Whether the function at issue is prosecutorial or non-prosecutorial under the Imbler framework	Conduct relates to plea negotiations and thus should be protected as prosecutorial.	Ordering a beating is non-prosecutorial and outside immunity.	Function not within prosecutorial duties; no immunity.
What is the proper application of the Mireles framework to this case	Mireles supports immunizing actions taken in a judicial-adjacent role during plea negotiations.	Mireles supports immunity where conduct is prosecutorial in nature and related to plea.	Objective function is ordering a beating; not prosecutorial; no immunity.

Imbler v. Pachtman, 424 U.S. 409 (1976) (absolute immunity for prosecutors for acts intimately related to judicial process)
Mireles v. Waco, 502 U.S. 9 (1991) (focus on function over act; immunity depends on function performed)
Buckley v. Fitzsimmons, 509 U.S. 259 (1993) (limits on prosecutorial immunity; function must be prosecutorial)
Burns v. Reed, 500 U.S. 478 (1991) (immunity constraints; not all actions warrant immunity)
Doe v. Phillips, 81 F.3d 1204 (1996) (plea bargaining conduct may be protected or not depending on authority)
Van de Kamp v. Goldstein, 555 U.S. 335 (2009) (administrative duties tied to judicial process can be immune when closely related)