Constitutional Law (Government Official Immunities)

Armstrong v. McAlpin — Study Notes

Armstrong v. McAlpin, 699 F.2d 79 (2d Cir. 1983)

Study notes for Armstrong v. McAlpin: professor notes, cold call prep, exam angles, and memory aids.

SEC officials are absolutely immune from damages for prosecutorial functions but entitled to qualified immunity for investigative acts and public statements.
Professor Notes

In Armstrong v. McAlpin, the Second Circuit addressed the issue of government official immunities, specifically distinguishing between absolute and qualified immunity for SEC officials engaged in enforcement actions. The court underscored that absolute immunity applies when officials perform prosecutorial functions, thereby allowing them to initiate and prosecute SEC actions without fear of subsequent liability. However, the decision also clarifies the limitations of this immunity by applying qualified immunity to investigative acts and public communications regarding ongoing enforcement matters, indicating the delicate balance between accountability and protection for government officials.

Cold Call Prep
  1. 1Explain the difference between absolute and qualified immunity as applied in this case.
  2. 2What were the main constitutional and common-law claims brought by Armstrong?
  3. 3How did the court apply the Harlow objective standard in determining qualified immunity?
  4. 4Discuss the significance of reputational harm in constitutional claims based on this case.
  5. 5What precedents did the court rely on in reaching its decision regarding prosecutorial functions?
  6. 6How does this case inform the current understanding of Bivens actions against government officials?
  7. 7In what scenarios might an SEC official not be protected by absolute immunity?
Mnemonic Device

AIM - Absolute Immunity for Motion; Qualified Immunity for Investigation and Messaging.

Distinguish From
CaseDistinction
Forrester v. WhiteForrester involved a judge's absolute immunity for judicial acts, whereas Armstrong distinguishes prosecutorial from investigative duties of SEC officials concerning immunity.
Bivens v. Six Unknown Named AgentsBivens established damages against federal officials for constitutional violations, while Armstrong clarifies the limits of such claims based on official functions.
Imbler v. PachtmanImbler held that prosecutors have absolute immunity for prosecutorial actions, similar to the findings in Armstrong, but emphasizes different contexts of official conduct.
Policy Arguments

For the Rule

Supporting absolute immunity under prosecutorial functions promotes vigorous enforcement of the law without fear of personal liability, thus enhancing the effectiveness of regulatory agencies.

Against the Rule

Opposing absolute immunity in enforcement actions argues that it may shield officials from accountability for misconduct, undermining the constitutional protections of individuals.

Class Discussion Points
  • The implications of absolute immunity for effective law enforcement versus the need for accountability.
  • The role of the Harlow test in evaluating qualified immunity claims and its impact on enforcement actions.
  • How the balance between government interests and individual rights is navigated in cases like Armstrong.
Exam Angle

This case could appear on exams in discussions of the limits of government official immunities and the differentiation between absolute and qualified immunity, particularly in the context of enforcement actions.

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