U.S. Court of Appeals for the Ninth Circuit
Estate of Lacy Lloyd Thomas v. Clark County Nevada
August 31, 2026
Summary
The court affirmed dismissal of the claim against Mitchell because his challenged conduct consisted of traditional prosecutorial functions protected by absolute immunity. It also affirmed summary judgment for Clark County because the Estate presented no pattern of similar constitutional violations or evidence that the County was deliberately indifferent to deficiencies in its Brady training and oversight. The court reviewed both rulings de novo.