Canen v. Chapman

Dist. Ct. did not err in granting defendant-fingerprint expert’s motion for summary judgment in plaintiff’s section 1983 action alleging that defendant had violated Brady, 373 US 83, when he withheld fact that he lacked qualifications to perform latent fingerprint analysis when testifying that latent fingerprint at crime scene matched plaintiff’s fingerprint, where plaintiff was ultimately convicted of murder charge, which was subsequent overturned after another expert ruled out plaintiff as source of said fingerprint. Defendant was entitled to qualified immunity, since defendant’s failure to disclose his lack of training as latent print examiner could not be viewed as violation of any clearly established right, and since neither prosecutor nor defendant lawyers elected to ask defendant to identify differences between latent and known fingerprints or to explain his training in one discipline as opposed to another discipline. Also, to extent plaintiff’s allegation focused on defendant’s actual testimony and his preparation for said testimony, defendant was protected by absolute immunity.