In 2018, Robert Goldsmith ran for sheriff of Tippecanoe County, Indiana, and had several deputies support his candidacy. Lieutenant Randall Martin did not support Goldsmith. Instead, Martin reported colleagues for unlawfully campaigning for Goldsmith while in uniform, maintaining that their conduct violated both department rules and state law. Goldsmith was elected in November 2018 and took office in January 2019. Martin alleged that tensions between him and officers aligned with Goldsmith continued after the election.
In late 2020, Martin allegedly used excessive force during two arrests. Although neither arrestee filed a complaint, Goldsmith initiated an internal affairs investigation and suspended Martin. Martin invoked his statutory right to a public hearing before the Sheriff’s Merit Board under Indiana Code § 36-8-10-11(a). Martin alleged that in the lead-up to the hearing, Goldsmith took steps to ensure the investigation and hearing would be biased. He claimed the sheriff replaced internal affairs personnel with officers selected for political loyalty, assigned one of the officers Martin had previously reported to conduct the investigation, and manipulated the merit board’s composition by replacing members traditionally favorable to Martin with his own “hand-picked” selections.
Believing the hearing process would be unfair, Martin proposed resigning if the charges were withdrawn and he received a neutral reference. A written agreement reflected those terms, and he resigned effective May 3, 2021. That same day, prosecutors Patrick Harrington and Jason Biss circulated Brady/Giglio materials, asserting that Martin’s reports conflicted with body-camera footage. They sent a template-style disclosure to local defense attorneys, emailed Martin’s part-time employer stating his testimony would be “unusable,” and later filed disclosures in criminal cases in which Martin had been involved. Martin alleged that this immediate dissemination showed the promise of a neutral reference and withdrawal of charges was illusory and that he was induced to forgo his statutory hearing through deception.
Martin filed a federal lawsuit under 42 U.S.C. § 1983, alleging that Goldsmith, Harrington, and Biss conspired to deprive him of procedural due process by inducing his resignation through “material misrepresentation[s]” and then publicizing the allegations. The district court dismissed on three grounds: absolute prosecutorial immunity, qualified immunity, and the conclusion that Martin had voluntarily resigned and waived any due process claim. On appeal, the Seventh Circuit affirmed in part and reversed in part.
On absolute immunity, the Court applied the functional test. Prosecutors are absolutely immune for conduct “intimately associated with the judicial phase of the criminal process,” including Brady/Giglio disclosures filed in criminal cases. The Court affirmed dismissal as to those court-filed disclosures. But the Court reasoned that the broader dissemination of that information — such as sending template disclosures to the bar and warning municipal employers — was not “case-driven advocacy” and therefore not entitled to absolute immunity. The Court therefore reversed dismissal to that category of conduct.
On voluntary resignation, the Court rejected the district court’s waiver theory. While employees who resign “voluntarily relinquish” due process protections, a resignation induced by “material misrepresentation[s]” may be coerced. Martin plausibly alleged he gave up his statutory hearing based on false assurances about withdrawn charges and a neutral reference. The Court therefore also reversed dismissal on those grounds.
On qualified immunity, the Court emphasized that the claim was not that Brady/Giglio disclosures themselves were unlawful, but that defendants induced Martin to resign through misrepresentations about the consequences. Circuit precedent clearly established that public employees have a constitutional right not to be induced to resign through such misrepresentations. Therefore, the Court concluded that at the pleading stage, defendants were not entitled to qualified immunity on the due process claim.
The Seventh Circuit therefore affirmed dismissal only as to Brady/Giglio disclosures filed in criminal cases that were protected by absolute immunity, and reversed dismissal as to the broader dissemination conduct and the due process claim, remanding for further proceedings.
Martin v. Goldsmith, 2025 WL 3769723 (7th Cir. Dec. 31, 2025).