In recent decisions, the Supreme Court has qualified the common-law immunities provided other government officials when suit is brought against them under section 1983. Federal officials were immune from suit58 until the Supreme Court recently modified that rule in Butz v. Economou.59 The prior absolute immunity afforded state officials60 was also qualified in Scheuer v. Rhodes."61 Longstanding law holding municipalities immune62 was overturned when the Court recently held that local governments were intended to be included among the "persons" to which section 1983 applies. Yet, in the face of these trends, the doctrine of judicial immunity has held fast. The most solid conclusion to be drawn from Sparkman v. Stump is that regardless of the degree of injury resulting from judicial conduct, the judiciary will continue to immunize its brethren with a generous hand.
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