Jeff Warren Cited by U.S. Court of Appeals for the Seventh Circuit
In a New Year’s Eve decision, the United States Court of Appeals for the Seventh Circuit cited Jeff Warren’s 2022 Wake Forest Law Review article in reversing the dismissal of a Fourteenth Amendment claim against two Indiana prosecutors who wrote a letter declaring a deputy sheriff “unusable” as a witness in future cases—effectively foreclosing his ability to obtain gainful employment. See Martin v. Goldsmith, No. 23-2277, 2025 WL 3769723, at *3 (7th Cir. Dec. 31, 2025). Citing with approval the analysis in Jeff’s article, the Seventh Circuit explained that prosecutors are not entitled to absolute immunity for writing “Giglio letters” because such letters are “solely administrative” and “not a part of a prosecutor’s duties.”
This marks the second time Jeff’s article has been cited by an appellate court. The first citation came from the Pennsylvania Commonwealth Court in Corbo v. Chester County, 336 A.3d 1 (Pa. Commw. Ct. 2025), where the court reversed a trial court’s extension of absolute immunity to a prosecutor who maintained a blacklist of officers purportedly lacking sufficient credibility to testify.
Jeff is a trial lawyer in the firm’s litigation group. His practice includes constitutional litigation, medical malpractice defense, and products liability defense.