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Keywords

lawsuitdamagesliabilitypublic defenderpunitive damagespiracy

liabilityappealtrialpublic defenderrespondentpiracy

Related Cases

Tower v. Glover, 467 U.S. 914, 104 S.Ct. 2820, 81 L.Ed.2d 758

Facts

Billy Irl Glover, represented by public defenders Bruce Tower and Gary Babcock, was convicted of robbery in Oregon. After his conviction, Glover filed a petition for post-conviction relief, claiming that his public defenders conspired with state officials to secure his conviction. He subsequently filed a federal lawsuit under 42 U.S.C. § 1983, seeking punitive damages based on the same allegations. The District Court dismissed the case, asserting that public defenders were absolutely immune from liability, but the Ninth Circuit reversed this decision.

Petitioner Tower, the Douglas County, Ore., Public Defender, represented respondent at a state robbery trial that resulted in respondent's conviction, and petitioner Babcock, the Oregon State Public Defender, represented respondent in his unsuccessful appeal from this and at least one other conviction.

Issue

Whether public defenders can be held liable under 42 U.S.C. § 1983 for alleged conspiratorial actions with state officials that deprive their clients of federal rights.

Rule

Public defenders are not immune from liability under § 1983 for intentional misconduct when they conspire with state officials to deprive clients of their constitutional rights.

State public defenders are not immune from liability under § 1983 for intentional misconduct by virtue of alleged conspirational action with state officials that deprives their clients of federal rights.

Analysis

The Court analyzed the allegations of conspiracy and determined that they sufficiently demonstrated conduct 'under color of' state law. It noted that while public defenders typically do not act under color of state law in their defense roles, their involvement in a conspiracy with state officials changes this dynamic. The Court also examined the historical context of immunity and concluded that public defenders do not enjoy immunity for intentional misconduct.

Although appointed counsel in a state criminal prosecution does not act “under color of” state law in the normal course of conducting the defense, Polk County v. Dodson, 454 U.S. 312, 102 S.Ct. 445, 70 L.Ed.2d 509, an otherwise private person acts “under color of” state law when engaged in a conspiracy with state officials to deprive another of federal rights, Dennis v. Sparks, 449 U.S. 24, 101 S.Ct. 183, 66 L.Ed.2d 185.

Conclusion

The Supreme Court affirmed the Ninth Circuit's ruling, allowing Glover's case to proceed, and clarified that public defenders are not immune from § 1983 liability for intentional misconduct.

The judgment of the Court of Appeals for the Ninth Circuit is affirmed. The case is remanded for further proceedings consistent with this opinion.

Who won?

Billy Irl Glover prevailed in the case as the Supreme Court ruled in his favor, allowing his claims against the public defenders to proceed based on the conspiracy allegations.

Petitioners concede, and the Court of Appeals agreed, that Glover's conspiracy allegations 'cast the color of state law over [[[petitioners'] actions.'

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