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Judges and criminal investigations

Surgret Urania Doss v. Holder

Updated Nov 12, 2026

In brief

Where it stands
Dismissed

Petition denied.

What it’s about
Doss asked the Supreme Court to review the appeals court’s dismissal of her Fourth Amendment claim that officials pursued one charge without probable cause, conspiracy claims involving officers from separate government entities, and claims about a judge’s alleged investigation of her property records.
Who it affects
The appeals court's dismissal remains in place for Doss, but the Supreme Court did not decide whether her claims were valid.

Summary: written with AI from the case record.

Illustration for Surgret Urania Doss, Petitioner v. Gregory P. Holder, et al.
Conceptual illustration · AI-generated

What it's about

The Court refused to hear the case (denied the petition) and did not decide those issues.

Doss's petition raised questions about assessing the legal basis for a single charge, claims against officers from different agencies who allegedly worked together, and whether legal protection for judges covers alleged investigative acts.

Question presented

1. Whether a court of appeals may affirm dismissal of a Fourth Amendment malicious-prosecution claim arising from a single charge without conducting the charge-specific probable-cause analysis required by Chiaverini v. City of Napoleon, Ohio, 602 U.S. 556 (2024), to the only charge alleged. 2. Whether the intra-corporate conspiracy doctrine under which agents of a single legal entity cannot conspire among themselves bars 42 U.S.C. §§1983 and 1985(3) conspiracy claims against officers of legally distinct governmental entities, a question this Court expressly left open in Ziglar v. Abbasi, '582 U.S. 120 (2017). 3. Whether absolute judicial immunity extends to a judge's non-adjudicative acts; independently researching a litigant's property records, concluding that a crime had been committed, and directing law enforcement to investigate, where the functional test of Forrester v. White, 484 U.S. 219 (1988), classifies such acts as executive rather than judicial, and where, under Malley v. Briggs, 475 U.S. 335 (1986), a complaining witness enjoys no absolute immunity at common law.

Documents

1

Docket activity

6
  • New analysis added

    Nov 12, 2026 · Court records

  • AI analysis generated: Case Briefing

    Nov 12, 2026 · Generated

  • AI analysis generated: Decision Record

    Nov 12, 2026 · Generated

  • Case data updated: summary, question_presented, generation_metadata

    Nov 12, 2026 · Court records

  • Case data updated: question_presented, extraction_metadata

    Nov 12, 2026 · Court records

Show 1 more
  • Brief added: Petition

    Jul 6, 2026 · Court records

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.

Checked Nov 12, 2026Methodology

Court records and filings

Reporting and analysis