What personal immunities are available to tribal officials?

QUESTION PRESENTED In Lewis v. Clarke 137 S.Ct. 1285 (2017) this Court explained tribal officials sued in their personal capacities could avail themselves of personal immunity defenses. But Lewis did not address the nature of the personal immunities available to tribal officials. Below, a California Court of Appeal synthesized Lewis and California common law to hold absolute prosecutorial immunity protects the conduct of attorneys pursuing civil litigation on behalf of a tribal commercial enterprise. While the result flows naturally from California’s commonlaw, it is anathema to this Court’s absolute immunity jurisprudence. The question presented is: What personal immunities are available to tribal officials?