Buckley v. Fitzsimmons Case Brief

Facts of the Case

Petitioner Stephen Buckley brought an action under 42 U.S.C.S. § 1983, which sought damages from respondent prosecutors for allegedly fabricating evidence during the preliminary investigation of a highly publicized rape and murder in Illinois and making false statements at a press conference announcing the return of an indictment against Buckley. He claimed that when three separate lab studies failed to make a reliable connection between a bootprint at the murder site and his boots, the prosecutors obtained a positive identification from one Louise Robbins, an anthropologist in North Carolina who was allegedly well known for her willingness to fabricate unreliable expert testimony.  Thereafter, the prosecutors convened a grand jury for the sole purpose of investigating the murder, and 10 months later, respondent Fitzsimmons, the State’s Attorney, announced the indictment at the news conference. Buckley was arrested and, unable to meet the bond, was held in jail. Robbins provided the principal evidence against him at trial, but the jury was unable to reach a verdict. When Robbins died before Buckley’s retrial, all charges were dropped and he was released after three years of incarceration. In the § 1983 action, the District Court held that respondent prosecutors were entitled to absolute immunity for the fabricated evidence claim but not for the press conference claim. On appeal, the United States Court of Appeals for the Seventh Circuit ruled that respondent prosecutors had absolute immunity because the injuries suffered by Buckley occurred during criminal proceedings. After its judgment was vacated and remanded, the Seventh Circuit again ruled that the prosecutors were entitled to absolute immunity. The United States Supreme Court granted Buckley’s petition for certiorari review.


When an illegal resident agrees to voluntarily depart the United States and then files a motion to reopen removal proceedings, does the filing suspend the time period by which the illegal resident must depart the United States under the voluntary departure order?



Case Information

Citation: 509 US 259 (1993)
Argued: Feb 22, 1993
Decided: Jun 24, 1993
Case Brief: 1993