The US Court of Appeals for the Eighth Circuit ruled Monday that former St. Louis Circuit Attorney Jennifer Joyce was entitled to absolute immunity over her decision to prosecute former police officer Jason Stockley for first-degree murder.
In 2011 Stockley and another officer observed what they thought was a drug transaction, which led to a chase in which Stockley shot and killed the suspect. The St. Louis Metropolitan Police Department’s (SLMPD) Internal Affairs Division investigated the death, finding no basis for criminal prosecution. At that time, Joyce, the FBI, the US Attorney and the US Department of Justice Civil Rights Division all declined to prosecute Stockley.
In May 2016 the SLMPD Force Investigation Unit (FIU) reopened the investigation, following protests against Joyce’s decision not to prosecute Stockley. Before completing the investigation, FIU officers were told to return the police file to Joyce, who decided to prosecute Stockley for first-degree murder. Following a bench trial, Stockley was acquitted.
Stockley filed a claim in the US District Court for the Eastern District of Missouri in 2017, alleging that Joyce’s decision violated her own protocol of requiring an FIU investigation of a police shooting before any prosecutorial decision. He argued that she was not immune from liability for doing so.
He also alleged that Joyce announced in public settings that she had new evidence proving him guilty of first-degree murder, even though she did not. Stockley claimed that this violated his substantive due process rights and that it was also defamation. The district court dismissed the claims.
On appeal, the circuit court found that Joyce’s decision to end the FIU investigation and to charge Stockley with first-degree murder, “clearly falls within the prosecutorial function of initiating judicial proceedings.” She had absolute immunity from liability for that decision. Although not immune from liability for violating substantive due process, the court also found that Stockley failed to state a substantive due process claim against Joyce for her remarks. Stockley also failed to state a defamation claim against Joyce.
Because of this, the court affirmed the district court’s dismissal of the claims.
