Imbler v. Pachtman

Imbler v. Pachtman

In 1962, a man named Paul Kern Imbler was sentenced to die by the State of California, following his murder conviction for the murder of a grocery store owner in a botched holdup attempt. After receiving his death sentence, he attempted to obtain a stay—and one was granted, just a week before his execution was to have been carried out. In 1964, another stay was granted, this time two weeks before he was to be put to death. In 1971, though, allegations of prosecutorial misconduct came out against the prosecutors in Imbler's case, and he was judged to be not guilty based on new evidence. Imbler's lawsuit against the prosecutors charged with misconduct became Imbler v. Pachtman, a case which would set a standard for prosecutorial immunity in the United States.

Imbler's False Conviction

Imbler was taken into custody after he and another man were caught robbing a service station a little more than a week after the grocer's murder. The other man involved in this robbery died during their escape attempt. Imbler admitted that he had, in fact, robbed the service station, but denied his involvement with the murder or robbery at the grocery store 10 days before. The conviction made by the prosecutor in Imbler's case, Richard E. Pachtman, was based on eyewitness evidence.

However, when the case had to be retried (due to Pachtman having made false statements about Imbler's eligibility for parole if convicted), it turned out that the state's principal witness against Imbler, Alfred Costello, was a mental patient who had been diagnosed as a pathological liar by multiple mental health professionals for reasons unrelated to the Imbler case. Additionally, the line-up evidence presented in the case was handled poorly, making it much more likely that a false identification would be made by an eyewitness. The other witnesses that had been part of the 1962 trial could not be located, so the murder charges were dropped and Imbler was set free.

It was also revealed that Pachtman had known about the unreliability of the witness, and had chosen to use him on the stand anyhow—then covered up that information so that jurors did not have access to it in order to understand how much weight they should put on his testimony.

The Lawsuit

In Imbler v. Pachtman, Imbler asked for $2.7 million in damages to compensate him after prosecutors demonstrated “grievous mental cruelty” in soliciting false and damaging statements from a witness and hiding information from jury members.

According to Imbler, the prosecution had also conspired with police to delay charging Costello, the star witness, with writing bad checks, so that he could say that in spite of a criminal record, he no longer engaged in any criminal behavior.

The Supreme Court Ruling

The Supreme Court, in a unanimous decision, ruled that Imbler could not be awarded damages because prosecutors had “absolute immunity” for any conduct in the course of their prosecutorial duties. This doctrine has since been reinforced by other cases and even expanded as time has gone on. The court decided that allowing lawsuits like Imbler v. Pachtman to succeed would have a deleterious effect on public safety because it would “prevent the vigorous and fearless performance of the prosecutor's duty,” which they considered a key component of the justice system.