Immunity for false testimony
Rehberg v. Paulk
In brief
The Supreme Court left the appeals court’s ruling in place: grand-jury witnesses get the same protection as trial witnesses from Section 1983 suits based on testimony.
- Where it stands
- Decided
Decided · April 2, 2012 · Opinion by Justice Alito
- What it’s about
- Charles Rehberg sued investigator James Paulk over alleged false grand-jury testimony.
- Who it affects
- A grand-jury witness cannot be sued under Section 1983 based on that witness’s testimony, even when the plaintiff alleges it was false.
Summary: written with AI from the case record.
What it's about
The Supreme Court agreed with the lower court (affirmed), deciding that grand-jury witnesses have the same protection from damages suits under federal civil-rights law (§1983) based on their testimony as trial witnesses.
The dispute concerned a damages claim under federal civil-rights law, known as Section 1983.
Question presented
Are government officials who initiate prosecutions by providing false testimony in judicial proceedings absolutely immune from civil suit?
What the Court decided
Holding
A witness in a grand jury proceeding is entitled to the same absolute immunity from suit under §1983 as a witness who testifies at trial. 611 F. 3d 828, affirmed.
- Result
- Affirmed
The vote
- Majority author
- Samuel A. Alito, Jr.
What's next
The Eleventh Circuit’s ruling remains in place. Lower courts must apply the same protection when handling Section 1983 claims based on grand-jury testimony.
Documents
Opinions
Audio
Docket activity
New analysis added
AI analysis generated: Case Briefing
New analysis added
AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
Audio Recording added: Oral Arguments - Rehberg
Opinion added: Rehberg
More questions
- Did the Court decide whether Paulk’s testimony was false?
- No. The Court decided the immunity question, not whether Rehberg’s allegation was true.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.