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Keywords

defendantattorneynegligenceliabilitytrialmalpracticeprosecutorrespondent
defendantattorneyappealtrialmalpracticeprosecutorrespondent

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Ferri v. Ackerman, 444 U.S. 193, 100 S.Ct. 402, 62 L.Ed.2d 355

Facts

A Federal District Court appointed the respondent attorney to represent the petitioner, an indigent defendant, in a federal criminal trial. After the petitioner was convicted, he filed a malpractice suit against the attorney in Pennsylvania state court, alleging numerous instances of negligence during the trial. The trial court dismissed the complaint, asserting that the attorney was immune from liability, a decision that was upheld by the Pennsylvania Supreme Court, which relied on federal law regarding judicial immunity.

A Federal District Court, pursuant to the Criminal Justice Act of 1964, appointed respondent attorney to represent petitioner, an indigent defendant, in a federal criminal trial. After petitioner was convicted and pending his unsuccessful appeal, he sued respondent in a Pennsylvania state court for alleged malpractice in respondent's conduct of the federal criminal trial.

Issue

Whether an attorney appointed by a federal judge to represent an indigent defendant in a federal criminal trial is, as a matter of federal law, entitled to absolute immunity in a state malpractice suit brought against him by his former client.

The question is whether an attorney appointed by a federal judge to represent an indigent defendant in a federal criminal trial is, as a matter of federal law, entitled to absolute immunity in a state malpractice suit brought against him by his former client.

Rule

An attorney appointed to represent an indigent defendant in a federal criminal trial does not enjoy absolute immunity from malpractice claims under federal law, as the rationale for immunity applicable to judges and prosecutors does not extend to defense counsel.

404 Held: An attorney appointed by a federal judge to represent an indigent defendant in a federal criminal trial is not, as a matter of federal law, entitled to absolute immunity in a state malpractice suit brought against him by his former client.

Analysis

The Supreme Court analyzed the nature of the attorney's role as akin to that of privately retained counsel rather than public officials like judges or prosecutors. The court emphasized that the primary responsibility of appointed counsel is to serve the interests of their client, which is fundamentally different from the societal interests represented by other public officials. The court concluded that the fear of malpractice claims does not inhibit the performance of appointed counsel in the same way it might for judges or prosecutors.

The primary rationale for granting immunity to judges, prosecutors, and other public officials—namely, the societal interest in providing such officials with the maximum ability to deal fearlessly and impartially with the public at large—does not apply to court-appointed defense counsel sued for malpractice by his own client.

Conclusion

The Supreme Court reversed the Pennsylvania Supreme Court's decision and remanded the case, holding that federal law does not provide immunity for court-appointed counsel in a state malpractice suit brought by a former client.

The judgment of the Supreme Court of Pennsylvania is reversed, and the cause is remanded for further proceedings not inconsistent with this opinion.

Who won?

The petitioner prevailed in the case because the Supreme Court ruled that the attorney was not entitled to absolute immunity, allowing the malpractice claim to proceed.

The petitioner prevailed in the case because the Supreme Court ruled that the attorney was not entitled to absolute immunity, allowing the malpractice claim to proceed.

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