# Ennals

> District Court, D. Maryland · June 30, 2026

URL: https://www.frixlaw.com/law-library/cases/11358218

## Case

- **Full name:** Key’Marion Ennals v. State of Maryland et al.
- **Court:** District Court, D. Maryland
- **Decided:** June 30, 2026
- **Opinion:** 100trialcourt
- **Cited by:** 0 later opinions in the Frix Law Library

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## Opinion text

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND
.KEY’MARION ENNALS, oe oe
Plaintiff,

v. ‘ , .
* Civil No. 26-175-BAH
STATE OF MARYLAND ET AL.,
. *
Defendants.
* * * * * te * te * * * ok *
MEMORANDUM OPINION
This case arises from the alleged malicious prosecution of Plaintiff Key’ Marion Ennals
(“Ennals”) for the murder of Ja’len Woolford. In December of 2025, Ennals brought suit in the
Circuit Court for Dorchester County against the State of Maryland (the “State”), and state
prosecutors Amanda Leonard, Philip Donoho, and Ella Disharoon (the “prosecutor Defendants”)!
(collectively “Defendants”) alleging three counts of'malicious prosecution against all Defendants
(Counts I-III), one count of negligent training, hiring, supervision, and retention against the State
(Count IV), a count of negligence against all Defendants and gross negligence against the
prosecutor Defendants (Counts V-V]), and one count of indemnification against the State (Count

' Ennals has not made clear from the face of his complaint whether he is suing the prosecutor
Defendants in their individual or official capacities (or both). In such circumstances, “the court
must examine the nature of the plaintiff’s claims, the relief sought, and the course of proceedings.”
Biggs v. Meadows, 66 F.3d 56, 61 (4th Cir, 1995), Because Ennals seeks monetary damages, the
Court will assume he is suing defendants in their individual capacities. See, ¢.g., Parks v. Lowe,
Civ. No. 1:09CV00070, 2010 WL 545679, at *7 (W.D. Va. Feb. 12, 2010) (“Parks has not asserted .
that the defendants acted in accordance with any policy or custom, and he is seeking monetary
damages, which indicates he is suing the defendants in their individual capacities.”), report and
recommendation adopted, No. 1:09CV00070, 2010 WL 753335 (W.D. Va. Mar. 1, 2010), aff'd,
407 F. App’x 643 (4th Cir. 2011).

ECF 3. In January of 2026, the State of Maryland removed the case to this Court. ECF 1.
Pending before the Cour is Defendants’ motion to dismiss for failure to state a claim. ECF □□
Ennals filed an opposition, ECF 16, and Defendants filed a reply, ECF 20. All filings include,
memoranda of law.’ The Court has reviewed all relevant filings and finds that no hearing is □
necessary? See Loc. R. 105.6 (D. Md. 2025). Accordingly, for the reasons stated below,
Defendants’ motion to dismiss is GRANTED. □
I. | BACKGROUND
A. Factual Background
On November 18, 2021, Ja’len Woolford was murdered in Cambridge, Maryland. See ECF
3,. at 4 q 13. On January 4, 2022, “Officer Hallman of the Maryland State Police Department
interviewed” Deaveon J ohnson “and obtained a confession regarding the murder of Ja’len
Woolford.” Jd. at 4-5 14-15. During that interview, Johnson “name[d] a slew of individuals
may have had some involvement with the shooting under the premise that Officer Hallman
would speak with the prosecutor and ensure that Mr. Johnson received a deal.” Jd. at 5 { 16.
Ennals was one of the individuals named. See id. After Johnson’s confession, “Officer Hallman
filed an Application for!Statement of Charges against Mr. Ennals.” Id. 417. “Around 9:00 p.m.
that day, [ ] Ennals voluntarily walked into the Cambridge City Police Department after learning
there was a warrant for his arrest.” Id. Officer Hallman then interviewed Ennals, “who repeatedly
denied involvement” in Woolford’s death. Jd. 4 18. The same night, “Ennals was arrested and’
processed at the Cambridge Police Department.” Jd, Ennals had no prior criminal history. See □□
id. 119. .

2 The Court references all filings by their respective ECF numbers and page numbers by the ECF-
generated page numbers at the top of the page.

_ 3 Accordingly, Ennels’ vonditional request for a hearing, ECF 16, at 50, is DENIED.
\ 5 . □

. On March 18, 2022, Johnson was charged with first- and second-degree murder and several
other crimes related to Woolford’s death. Id. § 20. Ennals was held without bond throughout this

_ time and for months after, until September 27, 2023—a total of 631 days. Id. at 6 4{21. “Ennals’
sister died while he was incarcerated.” Jd, at 17 ¥ 94. “Ennals filed a motion for compassionate
release to allow [ ] Ennals to be transported to her funeral,” which Leonard opposed, and ultimately
Judge Karen Dean, the state judge presiding over his case, “denied [ ] Ennals’ motion and [ ]
‘Ennals was not permitted to attend his sister’s funeral.” Id
In October of 2022,. the State and Johnson reached a plea agreement. See id at 6 1 25.
Johnson agreed to plead guilty to first degree murder and, “fijn return for [ ] Johnson’s testimony
‘against [ ] Ennals, the State agreed to enter a nolle prosequi to all other counts of the indictment
and recommend that [ ] J ohnson receive a sentence of Life Imprisonment, suspending all but forty
years, with five years of supervised probation, to be served under the Patuxent Youthful Offenders
‘Program.” Jd. “Johnson was ultimately sentenced to Life Imprisonment, suspending all but

twenty-five years, with five years’ supervised probation.” Id.
On February 15, 2023, Officer Hallman and Donoho interviewed another individual related
.to this matter, Gregory Lamont Cottman, /d, at 7 § 27. Cottman stated that he “did not think
_Ennals did anything because Johnson was bragging about the shooting.” Jd. § 29. In March of
2023, Ennals’ trial was scheduled for August 21, 2023. Id. at 8 733. Shortly thereafter, Ennals’
"counsel began seeking discovery from the State, including the production of “exculpatory evidence
or evidence that tends to impeach the State’s witness.” Jd. 35. In April of 2023, Leonard made
a digital discovery drive partially accessible to Ennals’ counsel and represented “that the State was □
not in possession of any Brady or Giglio information.” Jd. at 9 440. In the lead up to trial, Ennals
requested that Leonard disclose information related to the investigation.. See id. 42-43. Leonard

did not disclose the Cottman interview until just eleven days before trial, despite the fact that
“Leonard ... had personal knowledge of the interview at the same time it occurred.” fd. at 10
19 45-46. Even after this disclosure, Ennals’ counsel had to follow up to obtain the full interview,.
recording, and handwritten notes prepared during. See id. at 12 [].58-61. .
Seven days before trial, Ennals alleges that “Leonard and her office had committed
multiple ethical and legal violations,. failed: to provide additional notes mentioned in the report,
failed to file her sérvicel of discovery notice with the court, and still failed to provide a finalized
list of her trial witness and trial evidence disclosures that are mandatory and must be done without
request under Md. Rule 4-263.” Id. at 13 765 (emphasis omitted). On September 25, 2023, Ennals
filed an emergency motion to dismiss and for lack of speedy trial. Jd at 14 969. On September
27, 2023, the state court granted Ennals’ separate motion to disqualify Leonard, Disharoon, and
the State’s Attorney’s Office for Dorchester County “as the result of the State withholding
exculpatory evidence from the defense for over seven months and eventually providing it... □□
the eve of trial.” id [ 72-73. At that point, Ennals’ case was postponed “indefinitely for the
assignment of specially assigned counsel.” Jd. at 15 977. In October of 2023, Jonathon Church,
an Assistant State's Attorney from Prince George’s County, was appointed as special prosecutor
in Ennals’ case. Jd. 178.

That same month Bnnals alleges that Church met with Judge,S. James Sarbanes, who
“advised that at least one member of the State’s Attorney’s office, Defendant Disharoon, engaged
in an ex-parte conimunication with Judge Dean prior to the September 27, 2023 hearing.” Id. □
79. “While Judge Sarbanes did not disclose the actual text surrounding the communication, despite
a request to do so, he did advise that [] Disharoon texted Judge Dean sometime after [Ennals’
defense attorney] uncovered the state’s failure to disclose exculpatory evidence, and[]Disharoon

-said that she was not part of what was about to become public.” Jd Ennals’ counsel was advised
of this ex-parte communication and took measures to get further information. /d. at 15-16 §§ 81-
82. :

Eventually, Disharoon’s counsel provided fivo texts exchanged between Disharoon and
Judge Dean—one from July 20, 2022 and another on September 25, 2022. Jd. at 16 9] 84-88. The
first involved Disharoon advising Judge Dean that a motions hearing in Ennals’ case needed to be
postponed. See id. 185, The second was the communication acknowledged by Judge Sarbanes in
his conversation with Church, which involved Disharoon texting Judge Dean to say, presumably
in reference to Ennals’ case, “I have nothing to do with anything that might be filed over the next
few days. Only been in this case for a couple weeks. Just fyi...” Jd. at 16-17 4 88. “To date,”
Ennals alleges that he has not been “permitted to obtain additional documents between the court
and Defendants other than [ ] Disharoon’s alleged limited texts.” /d at 17991. □
“Bnnal’s criminal trial began on August 26, 2024, and it lasted four days.” Jd 92. “A

jury returned a not guilty verdict on all counts within 18 minutes.” Jd 993. □
B. Procedural History . □□
Ennals now brings suit against Defendants as a result of what he argues was Defendants’
‘malicious prosecution of him for the murder of Woolford. See ECF 3, at 2] 1. Ennals’ complaint
asserts seven counts in total. See id. at 17-32. In Count I, Ennals asserts a malicious prosecution
claim arising under Articles 24 and 26 of the Maryland Declaration of Rights against all
‘Defendants. Jd. at 17-19. Ennals alleges that Defendants “deprived Plaintiff of his rights □□□□□
Articles 24 and 26 of the Maryland Declaration of Rights by falsely prosecuting Plaintiff after
discovering exculpatory information, by improperly withholding evidence from Plaintiff and
‘Plaintiff's counsel, engaging in ex parte communication with the court to obtain improper delays
in violation of Plaintiff's speedy trial rights, and engaging in other misconduct that deprived

Plaintiff of his liberty.”, Jd. at 18 98. Ennals also argues that Defendants “falsified and/or
misstated vital information in-their court filings, in communication with Plaintiffs counsel, and in
reports, including, but ot limited to, the reports relating to the exculpatory interview of [ 1
Cottman.” fd. ¥ 100. In Count II, Ennals asserts another malicious prosecution claim against all
Defendants arising under the Fourth Amendment. See id. at 20-22. Count III also asserts a
malicious prosecution claim against all Defendants, presumably arising under Maryland common

law. See id. at 29-24,
In addition to those malicious prosecution, claims, Ennals asserts a negligent training,
hiring, supervision, and retention claim against the State. See id, at 24-25. In Count IV, Ennals
asserts that the State had a “duty to ensure State’s Attorneys, Assistant State’s Attorneys, and
Assistant Attorneys General are trained to conduct their prosecutorial activities within
constitutional bounds” and to ensure. they are “competent,” as well as “a duty to discipline and/or’
fire attorneys who failed to conduct their duties in a constitutional manner.” Id. at 24 | 129.
However, Ennals alleges that the “State breached its duty to ensure that the Defendants were

competent and trained in the state and federal constitutional limits of their prosecutorial authority,
which led the Defendants to believe that they could unconstitutionally prosecute Plaintiff without
probable cause, withhold exculpatory evidence from Plaintiff and Plaintiffs counsel, engage in ex
parte communication with the court to obtain improper delays in violation of Plaintiff's speedy.
trial rights, and engage in other misconduct that deprived Plaintiff of his liberty.” Jd. 130.
Finally, Ennals asserts a claim of gross negligence (Count V) against Leonard, Doncho,
and Disharoon, as well as a claim of negligence (Count VI) under Maryland common law against,
all Defendants, for the same conduct described above related to the prosecution of his case, along
with a count for indemnification against the State under the Maryland Tort Claims Act (“MTCA”).

See id, at 26-29. On January 22, 2026, Defendants filed the pending motion to dismiss, ECF 5,

which became ripe for review on April 3, 2026, ECF 20. The Court now resolves the pending
motion.
Il. LEGAL STANDARD □□
Federal Rule of Civil Procedure 12(b)(6) governs dismissals for failure to “state a claim
upon which relief can be granted.” In considering a motion under this rule, courts discount legal □
- conclusions stated in the complaint and “accept as true all of the factual allegations contained in
‘the complaint.” Erickson y. Pardus, 551 U.S. 89, 94 (2007); see also Ashcroft v. Iqbal, 556-U.8.
662, 678 (2009). A court then draws all reasonable inferences in favor of the plaintiff and
considers whether the complaint states a plausible claim for relief on its face. Nemet Chevrolet,
‘Ltd. y. Consumeraffairs. com, Inc., 591 F.3d 250, 253 (4th Cir. 2009). “A claim has facial
plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable
inference that the defendant is liable for the misconduct alleged.” Iqbal, 556 U.S. at 678.

. “The complaint must offer ‘more than labels and conclusions’ or ‘a formulaic recitation of
the elements ofa cause of action[.]’” Swaso v. Onslow Coty Bd. of Educ. , 698 F. App’x 745, 747 □
(4th Cir, 2017) (quoting Bel? Ail, Corp. v. Twombly, 550 U.S. 544, 555 (2007). At the same time,
“complaint will not be dismissed as long as [it] provides sufficient detail about [the plaintif's
claim to show that [the plaintiff] has a more-than-conceivable chance of success on the merits.”
+ Owens v. Balt. City State's Att’ys Off, 167 F.3d 379, 396 (4th Cir. 2014).
ll. ANALYSIS
A. The Prosecutor Defendants
Apart from the State itself, Ennals has brought this suit against three state prosecutors. It
is perhaps unsurprising, then, that Defendants primarily rest their motion to dismiss on the □
‘application of prosecutorial immunity to the claims asserted, See ECF 5-1, at 6-10. The Supreme

Court has held that prosecutors are absolutely immune from damages liability when they act as
advocates for the State. See Imbler v. Pachtman, 424 U.S. 409, 430-32, (1976). “That decision:
rests on an ‘important public policy’ justification.” Savage v. Maryland, 896 F.3d 260, 268 (4th
Cir. 2018) (quoting Carter v. Burch, 34 F.3d 257, 261 (4th Cir. 1994)). “The public trust of the

prosecutor’s office would suffer were the prosecutor to have in mind his own potential damages.
liability when making prosecutorial decisions—as he might well were. he subject to □□□□
liability.” fd. (internal quotation marks omitted) (quoting Van de Kamp v. Goldstein, 555 U.S.
335, 341-42 (2009)). Although this immunity leaves those “‘genuinely wronged’ without a.
- remedy against prosecutors acting for malicious or unlawful purposes,” the Supreme Court has
concluded that “the importance of shielding prosecutorial decision-making from the influence of
personal liability concerns . . . outweigh[s] that harm.” /d. (first quoting Imbler, 424 U.S. at □□□□
then citing Carter, 34 F.3d at 261). □

“Given these costs, however, the Court has been careful to limit the scope ofa prosecutor’s
absolute immunity.” Jd “Because prosecutorial immunity ‘safeguards the process, not the
person,” it applies only, to conduct that is ‘intimately ‘associated with the judicial phase of the
criminal process.” Jd. (internal quotation marks omitted) (quoting Nero v. Mosby, 890 F.3d 106,
117-18 (4th Cir. 2018)). “In deciding whether an action meets that standard,” the Court applies
“a ‘functional approach,’ looking to ‘the nature of the function performed,’ without regard to ‘the
identity of the actor who performed it.’” Jd. (internal quotation marks omitted) (quoting Nero, 890
F.3d at 118). The focus should remain “on the ‘conduct for which immunity is claimed, not on
the harm that the conduct may have caused or the question whether it was lawful.’” Id. (quoting
Buckley v. Fitzsimmons; 509 U.S. 259, 271 (1993).

“In applying this functional approach, the Supreme Court has ‘distinguished between
advocative functions and investigative or administrative functions, holding that the former enjoy
absolute immunity but the latter do not.” Nero, 390 F.3d ‘at 118 (citing Kalina v. Fletcher, 522
U.S. 118, 125-26 (1997)). “A prosecutor acts as an advocate when she professionally evaluates
evidence-assembled by the police, decides to seek an arrest warrant, prepares and files charging
documents, participates ina probable cause hearing, and presents evidence at trial.” Jd. (internal
citations omitted). “In contrast, a prosecutor doés not act as an advocate, but rather in an
investigative or administrative capacity, when she gives legal advice to police during an
investigation, investigates a case before a probable cause determination, and personally attests to
truth of averments in a statement of probable cause.” Jd. (internal citations omitted).
Ennals argues that prosecutorial immunity does not apply here. See ECF 16, at 14. He
asserts that “[t]he purpose of prosecutorial immunity, in theory, is to protect the prosecutor from
‘harassment by unfounded litigation,’ such that the prosecutor does not ‘shade his decisions instead
of exercising the independence of judgment required by his public trust.’” Jd. (quoting Jmbler,
424 USS. at 423). Because the “doctrine arose from the recognition that a prosecutor’s judgment
and decision making should not be subject to civil suit lest potential liability for the consequences
of those decisions impede the prosecutor’s judgment,” Ennals argues prosecutorial immunity
‘should apply to “advocative decision making,” which he contends is not the conduct his suit ‘
challenges. Jd. at 14-15 (emphasis in original). But advocative decision making, as defined by _
the Fourth Circuit, constitutes exactly the kind of conduct for which Ennals seeks to hold the
‘prosecutor Defendants liable here.
In applying the functional approach, the Fourth Circuit has stated that “the timing of a

. prosecutor’s conduct is a key factor.” Annappareddy v. Pascale, 996 F.3d 120, 139 (4th Cir. 2021)

_ (citing Buckley, 509 Us. at 273). “Actions taken by a prosecutor after a. probable-cause
determination has been made generally are classified as ‘advocative’ functions — ‘relat[ing] to an
advocate’s preparation fn the initiation of a prosecution or for judicial proceedings’ — that trigger
absolute immunity[.]” Id. (emphasis in original) (first quotirig Nero, 89 F.3d at 118; and then ©

quoting Buckley, 509 U.S. at 272-73). “That includes, of course, the presentation of evidence at
trial, or before a grand jy after a decision to seek an indictment is made.” - Ia. (citing Buckley,
509 US. at 273). “By contrast, actions taken before probable cause is established are more likely
to be ‘investigative’ in hature — the same kind of function normally performed by detectives or
police officers — and therefore protected only by qualified immunity.” id. (citing the same). As
Defendants observe, “in this case, the alleged wrongful actions . . . begin after [] Ennals was
arrested, charged, and denied bail.” ECF 5-1, at 7. The allegations of wrongdoing related to □□□□
malicious prosecution counts “atise out of the alleged failure to timely fulfill discovery and Brady-
Giglio obligations and engaging in ex parte communications with the trial court judge.” Id. (citing
ECE 3, at 18-20 f 98-99, 110, at 22-23 § 123).
Although Ennals alleges that there “was no probable cause or justification for the
prosecution of Plaintiff” ECF 3, at 20 4 111, his complaint does not identify specific instances of
alleged wrongdoing by the prosecutor Defendants operating in their investigative capacity. Rather,’
as Ennals clarifies in hisjopposition, his “claims generally arise from two categories of misconduct:
Defendant Disharoon engaging in ex parte communication with the trial judge on multiple

occasions, and the Defendants’ failure to disclose the evidence arising out of the interview with.
Mr. Cottman on Februaiy 15, 2023.” ECF 16, at 23-24 (internal citation omitted). In addition to
the fact that it is not clear how the ex parte communications alleged in the complaint played into
decision to prosecute Ennals, “TcJourts have granted absolute immunity despite claims of ex,

10

parte communications with judges.” Fares v. U.S. INS., 29 F. Supp. 2d 259, 263 (WDNC.

1998) (collecting cases), aff'd, 11 F. App’x 137 (4th Cir. 2001). “What is more, courts have found
‘prosecutors and analogous attorneys immune from liability for claims of making false or

. defamatory statements in judicial proceedings, as well as for claims of eliciting false and
defamatory testimony from witnesses,” Id. (collecting cases). And well-established amongst
‘advocative functions is a prosecutor’s “decision as to whether [ ] evidence was exculpatory.”
Carter v. Burch, 34 F.3d 257, 262 (4th Cir. 1994); Annappareddy, 996 F.3d at 141 (“It is well
established . . . that the failure to disclose exculpatory evidence while a criminal proceeding is

pending is an ‘advocative’ function protected by absolute immunity. As the Supreme Court
explained in /mbler, the ‘deliberate withholding of exculpatory information,’ even if
unconstitutional, is considered part of the prosecutorial role for immunity purposes.” (citation
-omitted)). Because Ennals’ malicious prosecution, negligence, and gross negligence claims all
turn on these shared allegations about advocative prosecutorial conduct, they must be’ dismissed.
Ennals seeks to escape this conclusion by asking the Court to focus on the purpose of the □
immunity. To be sure, the doctrine of prosecutorial immunity is founded in part on the “concern
that harassment by unfounded litigation would cause a deflection of the prosecutor's energies from
his public duties.” Jmbler, 424 USS, at 423. But that does not mean “unfounded litigation” is a
prerequisite for the application of prosecutorial immunity. To the contrary, prosecutorial
immunity can “leave the genuinely wronged defendant without civil-.redress against a prosecutor
whose malicious or dishonest action deprives him of liberty.” Jd at 427. But that reality is
outweighed by “the broader public interest” recognized by the Supreme Court in Jmbler. □□□□ □
Anviappareddy, 996 F.3d at 139 (“We recognize that wher absolute prosecutorial immunity
applies ... it may in some cases lead to unfair results .... But as we have explained, the Supreme

Court has concluded that ‘important public policy justification[s])’ outweigh these harms.” (quoting
Savage v. Maryland, 896 F.3d 260, 268 (4th Cir. 2018)). .
Appearing to recognize the likelihood of the conclusion the Court now reaches with respect
to prosecutorial immunity, Ennals eloquently argues that “there is a good faith basis for a change’
in the law.” ECF 16, at 26 (emphasis omitted and capitalization altered). Ennals even suggests
that the Court “certify the challenge to prosecutorial immunity presented here to the Supreme
Court of Maryland,” pursuant to the Maryland Uniform Cettification of Questions of Law Act.-
ECF 16, at 32. The Court appreciates Ennals’ thorough research and thoughtful review of this area
of the law. See id. at 26-40. But the doctrine of prosecutorial immunity is well-settled, and it is
not this Court’s role to overturn decades of precedent. See Doe v. Chao, 511 F.3d 461, 465 (4th.
Cir. 2007) (“The principle that a district court may not violate the mandate of a circuit court of
appeals and may not alter the law of the case so established is basic.” (quoting United States v.
Henry, 709 F.2d 298, 306 (Sth Cir. 1983)). The claims asserted against the prosecutor Defendants
are dismissed.* .
B. The State □□
« A state waives its immunity under the Eleventh Amendment when it removes an action
to federal court.” Francis. v. Univ. of Balt., Civ. No. RDB-24-2295, 2025 WL 1952515, at *9 o.
Md. July 16, 2025) (citing Lapides v. Bd. of Regents of Univ. Sys. of Ga., 535 U.S. 613, 624 .
(2002)). And in the Fourth Circuit, “a state’s removal of a suit to federal court waives sovereign
immunity only if the state has consented to suit in its own courts.” Biggs v. N.C. Dep't of Pub.
Safety, 953 F.3d 236, 241 (4th Cir. 2020). Under the MTCA, the “General Assembly has partially
waived the State’s sovereign immunity by enacting SG § 12-104(a),” which provides the waiver

4 Because the Court disposes of the action on this ground, it does not reach Defendants’ arguments
that they are also statutorily immune from suit under the MTCA. See ECF 5-1, at 11. □

in “a tort action, up to $400,000 per claimant per incident of occurrence.” State v. Rovin, 246 A.3d
1190, 1207 (Md. 2021). The MTCA “contemplate[s] two possible outcomes where an individual
is State personnel has allegedly engaged in a tortious act or omission for which there is an
issue of.” Jd. “If the individual acts within the scope of the individual’s public duties and without
malice or gross negligence, the individual is entitled to State personnel immunity, and the State is

not entitled to sovereign immunity.” Jd at 1207-08. “By contrast, if the individual does not act
within the scope of the individual’s public duties or if the individual acts with malice or gross
negligence, then the individual is not entitled to State personnel immunity, and the State is entitled
to ‘sovereign immunity because sovereign immunity is not waived under that circumstance.” Jd.
at 1208. .
“That said, where the individual is entitled to a form of absolute immunity, e.g,
prosecutorial immunity or judicial immunity, neither the individual nor the State is civilly liable,
even if the individual is also entitled to State personnel immunity under the MTCA.” □□□ (emphasis
added). That principle applies in full force here. Given that the prosecutor Defendants “are entitled
to prosecutorial immunity, an absolute immunity,” for the claims discussed above, “the State
cannot be held civilly liable for their actions in this case.” Jd. at 1208-09. That principle extends
to the count of negligent training, hiring, supervision, and retention asserted solely against the
State. As the Supreme Court has explained, “[o]nce we determine that supervisory prosecutors
‘are immune ina suit directly attacking their actions related to an individual trial, we must find they
are similarly immune” for a “faulty training’ claim” like the type brought here, Van de Kamp □□
Goldstein, 555 U.S. 335; 346 (2009). Because the negligent training, hiring, supervision, and
‘retention claim turns on the same alleged misconduct the Court concludes is encompassed by

absolute, prosecutorial immunity, it is thus “directly connected with the prosecutor’s basic trial
advocacy duties,” id. at 346, and must be dismnissed.
IV. CONCLUSION:
t
For the foregoing reasons; Defendants’ motion to,dismiss is GRANTED, and the Clerk
will be directed to CLOSE this case. A separate implementing. order will issue. :

Dated: June 30,2026 | isi
os Brendan A. Hurson
United States District Judge

14

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/11358218. Public record. Not legal advice.