The following excerpt is from Burns v. County of King, 883 F.2d 819 (9th Cir. 1989):
In this circuit's leading post-Briscoe decision, Holt v. Castaneda, 832 F.2d 123, 127 (9th Cir.1987), cert. denied, --- U.S. ----, 108 S.Ct. 1275, 99 L.Ed.2d 486 (1988), we extended the Briscoe analysis to provide absolute immunity for a police witness at adversarial pretrial proceedings. We reviewed the decisions of other circuits in which absolute witness immunity has been extended to various nontrial proceedings, see Holt at 125-26, and concluded that there was no meaningful distinction between the considerations underlying Briscoe and the considerations that would support absolute immunity for witnesses in adversarial pretrial proceedings.
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