Judges and criminal investigations
Surgret Urania Doss v. Holder
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.

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
Docket activity
New analysis added
AI analysis generated: Case Briefing
AI analysis generated: Decision Record
Case data updated: summary, question_presented, generation_metadata
Case data updated: question_presented, extraction_metadata
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Brief added: Petition
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.