Does the defense of prosecutorial independence immunize law enforcement officers from damages suffered as a result of their actions?

The defense of prosecutorial independence immunizes law enforcement officers from damages suffered as a result of a prosecutor's independent decision to file a criminal complaint against an individual. The defense is governed by a split burden of proof. The decision to file a complaint is presumed to result from an independent judgment on the part of the prosecutor, but the plaintiff may rebut the presumption by introducing evidence that the decision to prosecute was influenced by pressure or misinformation from law enforcement officials. See Smiddy v. Varney, 665 F.2d 261, 266 (9th Cir.1981). If the plaintiff meets this burden of production, the burden of persuasion reverts to the defense to demonstrate that the decision to prosecute was truly independent. Id. at 267.