What happens when someone is killed by a federal officer—and no criminal investigation follows? In this episode, Jill connects Dr. Martin Luther King, Jr.’s final words to the modern-day death of Renée Good, then walks through the legal doctrines that shape accountability in the United States. You’ll learn how immunity works, why investigations matter, and what legal paths, however limited, may still exist when the system feels silent.
What happens when someone is killed by a federal officer—and no criminal investigation follows? In this episode, Jill connects Dr. Martin Luther King, Jr.’s final words to the modern-day death of Renée Good, then walks through the legal doctrines that shape accountability in the United States. You’ll learn how immunity works, why investigations matter, and what legal paths, however limited, may still exist when the system feels silent.
What You’ll Learn in This Episode
Why Dr. King’s final speech still speaks to moments of national confusion and grief
The story of Renée Good and why the absence of an investigation changes everything
What absolute immunity is and why it protects certain government functions
How immunity is tied to roles and actions, not people
What 42 U.S.C. § 1983 is and when it can be used
How qualified immunity makes civil accountability nearly impossible in many cases
Why criminal accountability depends on investigation
How the George Floyd case differs from Renée Good’s case
What supremacy clause immunity means for state prosecution of federal officers
Why complete evidence, not opinions or video clips, determines whether a case can move forward
How the Federal Tort Claims Act may offer one limited civil path for families
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The Death Readiness Podcast
Episode: 60
Title: What You Need to Know When Justice Feels Out of Reach
Host: Jill Mastroianni (Solo)
Published: January 23, 2026
What happens when someone is killed by a federal officer—and no investigation follows? Today, I connect Dr. King’s final words to the modern-day death of Renée Good, and walk through the legal doctrines that shape accountability in the United States. We’ll unpack absolute immunity, qualified immunity, and what options remain when the system seems silent. This is a heavy conversation, but a necessary one.
Welcome to the Death Readiness Podcast. This is not your dad’s estate planning podcast. I’m Jill Mastroianni, former estate attorney, current realist, and your guide to wills, trusts, probate and the conversations no one wants to have. If your Google search history includes, “Do I need a trust?” “What exactly is probate?” and “Am I supposed to do something with mom’s Will?” you’re in the right place.
As is the theme with my Friday episodes, I take a more holistic view of estate planning—and of human agency. Today, I’m going to share a few quotations and excerpts that have been sitting with me, starting with words spoken by Dr. Martin Luther King, Jr. on the eve of his assassination.
But before I begin with his words, I want to share a quote from someone else. Someone who isn’t known to the world—but who is loved beyond measure by me.
My daughter, April.
A couple of weeks ago, I was heading to Office Max to pick up a whiteboard for myself and a bulletin board for my husband. I asked April if she wanted anything while I was there. She thought for a moment and said she would really love a chalkboard for her bedroom.
April and I are very different.
I’m regimented. I bought two whiteboards—one for personal tasks, one for work—and immediately filled them with to-do lists. I measure my days by what’s unfinished.
The next morning, I walked past April’s bedroom and noticed she had already used her chalkboard. But not the way I use mine. She wasn’t tracking what she lacked or what she still needed to do.
She had written, simply:
“Welcome. You are amazing.”
So today, especially in a world that feels heavy, divided, and exhausted, I want to extend her words to you.
Welcome to today’s podcast. You are amazing.
April’s words remind me that even in heavy moments, there is still something luminous inside us. Something steady, something human.
And that brings me to the first voice I want to share with you today.
This past Monday, we honored the life and legacy of Dr. Martin Luther King, Jr., a man who understood, perhaps better than anyone, what it meant to stand in darkness and still believe in light.
What you’re about to hear were words he spoke on the eve of his assassination, words that feel hauntingly relevant today.
The day before Dr. King was gunned down outside the Lorraine Motel in Memphis, he had traveled to Memphis to support a sanitation workers’ strike.
He arrived sick—with a fever and a sore throat. He planned to rest that night and asked a close friend, Ralph Abernathy, to speak in his place.
But when his friend took the stage, he realized the room was waiting for King. The people hadn’t come for a substitute.
So King went to the stage. And he spoke.
I want you to hear a portion of what he said—and as you listen, imagine he is speaking not to a crowd in 1968, but to us, here, now, in 2026.
If I were standing at the beginning of time, with the possibility of a general and panoramic view of the whole human history up to now, and the Almighty said to me, ‘Martin Luther King, which age would you like to live in?’ I would take my mental flight by Egypt through, or rather across, the Red Sea, through the wilderness, on toward the promised land. And in spite of its magnificence, I wouldn’t stop there.
I would move on by Greece and take my mind to Mount Olympus. And I would see Plato, Aristotle, Socrates, Euripides, and Aristophanes assembled around the Parthenon as they discussed the great and eternal issues of reality.
But I wouldn’t stop there. I would go on, even to the great heyday of the Roman Empire. And I would see developments around there, through various emperors and leaders.
But I wouldn’t stop there. I would even come up to the day of the Renaissance and get a quick picture of all that the Renaissance did for the cultural and esthetic life of man.
But I wouldn’t stop there. I would even go by the way that the man for whom I’m named had his habitat. And I would watch Martin Luther as he tacked his 95 theses on the door of the church in Wittenberg.
But I wouldn’t stop there. I would come up even to 1863 and watch a vacillating president by the name of Abraham Lincoln finally come to the conclusion that he had to sign the Emancipation Proclamation.
But I wouldn’t stop there. I would even come up the early Thirties and see a man grappling with the problems of the bankruptcy of his nation. And come with an eloquent cry that we have nothing to fear but fear itself.
But I wouldn’t stop there. Strangely enough, I would turn to the Almighty and say, ‘If you allow me to live just a few years in the second half of the 20th century, I will be happy.’
Now that’s a strange statement to make, because the world is all messed up. The nation is sick. Trouble is in the land. Confusion all around. That’s a strange statement. But I know, somehow, that only when it is dark enough can you see the stars.
The next day—Thursday, April 4, 1968 at 6:05 p.m.—Dr. Martin Luther King, Jr. was shot and killed while standing on a balcony outside his motel room. His life—his courage, his moral clarity, and his commitment to human dignity—left a legacy that still echoes today.
In honoring Dr. King’s life and the values he stood for, I want to talk now about another death, the death of Renee Good, and what her story can teach us about how we as a society value human life, accountability, and public trust.
On January 7, 2026, Renée Good was fatally shot in Minneapolis, Minnesota, by an agent of the U.S. Immigration and Customs Enforcement.
An independent autopsy commissioned by her family found that she was shot 3 times – in her head, the right side of her chest and her right forearm.
Renee leaves behind three children, ages 15, 12, and 6. Renee’s former husband and father of her 6-year old little boy died in 2023.
By now, many of you have seen portions of the video captured from multiple angles. You have likely heard commentators offering different interpretations of what happened, or why it happened.
But here is one fact that no one disputes: Renee Good is dead as the result of gunshot wounds inflicted by a federal immigration agent in Minneapolis.
That fact, her death, is a profound tragedy.
When parents lose their daughter, when a woman loses her wife, and, especially, when children lose a mother, a terrible tragedy has occurred.
And it forces us to ask: Where do we go from here?
I think we start by looking back — not to relive pain, but to find direction.
We look back to the words of Martin Luther King, Jr. on the eve of his death:
“the world is all messed up. the nation is sick. trouble is in the land. confusion all around ... But I know, somehow, that only when it is dark enough can you see the stars.”
And who are the stars? We are. We are, as my daughter wrote on her blackboard, “amazing.”
We are the everyday people who choose to stand up for what we believe is right, and for what we believe is good.
But to stand up for what we believe is right and good, we need two things: we need to understand the facts and we need to understand the law as it exists today.
I’m an expert in estate planning law. That work teaches me about agency, about control over our lives, our choices, and our legacies. Estate planning is fundamentally about empowering ourselves to protect the people we love and the values we hold dear.
But life, and justice, aren’t confined to wills and trusts. Life is about how we love our country and what we believe that country represents. It’s about how we treat our fellow citizens and other members of our community, and how we hold systems accountable when harm occurs.
Today’s episode isn’t about sensationalism. It isn’t about finger-pointing or accusations. It’s about being informed — and empowerment through being informed.
Like you, I’ve seen people offer all kinds of interpretations of what happened in Minneapolis — different videos, opinions, and legal theories. What I want to do today is help us understand where our country stands under the law so that you can decide for yourself what you believe is right, what you believe is wrong, and what questions you want to explore more deeply moving forward.
And on this journey — the journey toward empowerment through education — I’m with you.
So let’s start with where things stand right now.
Todd Blanche, the Deputy Attorney General, issued a statement saying that there is “currently no basis for a criminal civil rights investigation” into the ICE agent who shot Renée Good.
And it’s that absence, the absence of an investigation, that I want to explore with you first.
Because a question naturally follows:
Does the lack of investigation even matter? Don’t federal officers—don’t ICE agents—have absolute immunity anyway?
So before we go any further, we need to understand what that term, “absolute immunity” actually is and who has it.
Absolute immunity is a form of legal protection that completely shields certain government actors from being sued for specific actions they take while performing certain official duties. It is unconditional. If it applies, the case cannot go forward—no matter how serious the harm.
And this is important: absolute immunity is not just immunity from paying damages later. It is immunity from being sued at all.
There is no statute that defines absolute immunity. There is no section of the U.S. Code I can read to you.
Absolute immunity—and qualified immunity, which we’ll talk about later—are judicially-created doctrines.
The courts’ concern has always been functional: How often would officials be sued? Would fear of lawsuits interfere with their ability to do their jobs?
Another critical point is that absolute immunity is tied to the function, not the person.
So even officials who receive absolute immunity only receive it when performing very specific tasks.
So who qualifies for absolute immunity?
Outside of those roles, absolute immunity does not apply.
But what does that actually look like in real life?
To answer that, I’m going to walk you through four U.S. Supreme Court cases—one involving prosecutors, one involving judges, one involving legislators, and one involving the President of the United States—so you can see how this doctrine works, not in theory, but in practice.
Then, we’ll talk about what that means for ICE agents—and for Renée Good’s family.
In each of these cases, the person bringing the lawsuit is seeking damages under a federal law, 42 United States Code Section 1983.
In plain English, Section 1983 allows individuals to sue state and local government officials when their constitutional rights have been violated. It’s one of the main civil rights enforcement tools in the United States.
So now let’s look at how absolute immunity works inside that framework.
The first case involves a prosecutor and was decided by the United States Supreme Court in 1976.
Paul Imbler had been wrongfully convicted of first-degree murder. He alleged that the prosecutor in his case had knowingly used perjured testimony to secure his conviction.
After his conviction was overturned, Mr. Imbler sued under Section 1983, seeking damages for the years he had lost in prison.
Now remember: prosecutors have absolute immunity — but only for prosecutorial acts.
So the question became: Was knowingly using false testimony a prosecutorial act?
The Supreme Court said yes.
It held that the prosecutor was absolutely immune from liability under Section 1983.
And here’s how the Court explained that decision:
“Although such immunity leaves the genuinely wronged criminal defendant without civil redress … the alternative of qualifying a prosecutor’s immunity would disserve the broader public interest by preventing the vigorous and fearless performance of the prosecutor’s duty that is essential to the proper functioning of the criminal justice system.”
That brings us back to what I said earlier: absolute immunity is about protecting the function, even when the outcome feels morally wrong.
Next, let’s move to judges. They have absolute immunity for judicial acts — but what counts as a judicial act?
The Supreme Court has interpreted that very broadly.
In a 1991 case, Mireles v. Waco, Howard Waco, a Los Angeles public defender sued Judge Raymond Mireles under Section 1983.
Mr. Waco alleged that after he failed to appear when court was called, Judge Mireles became angry and ordered two police officers to forcibly drag him into the courtroom.
Mr. Waco claimed the officers used excessive force, cursed him, slammed him through the courtroom doors, and that the judge knowingly approved what they did.
So the question was: Was this a judicial act?
The Supreme Court said yes.
It ruled that:
“A judge’s direction to court officers to bring a person who is in the courthouse before him is a function normally performed by a judge.”
Because Mr. Waco was being brought into court for a pending case, the judge was acting in his judicial capacity, even if the conduct was abusive.
As a result, Judge Mireles had absolute immunity, and Mr. Waco’s Section 1983 claim could not move forward.
Now, this is another result where the law feels deeply uncomfortable.
The purpose of judicial immunity is not to protect bad behavior. It is to protect judicial independence.
The idea is that judges must be free to make unpopular, controversial, and even mistaken decisions without fear of being personally sued. If every ruling could trigger personal liability, judges would hesitate, second-guess, and self-censor — and justice itself would become distorted.
So the law makes a tradeoff.
It protects the function of judging, even when the outcome is hard to accept.
Next, let’s move to legislators.
They, too, receive absolute immunity, but only for their legislative functions.
The case here is Bogan v. Scott-Harris, decided by the U.S. Supreme Court in 1998.
Ms. Scott-Harris was the only employee in a small city department in Fall River, Massachusetts. After she filed a complaint against another city employee, the city council voted to eliminate her entire department.
She sued under Section 1983, claiming the decision was motivated by racial discrimination and retaliation for exercising her First Amendment rights.
So the question became:
Was this a legislative act or an act of personal retaliation?
The Supreme Court said it was legislative.
And because it was legislative, the city officials were entitled to absolute immunity—even if their motives were questionable.
The Court explained that legislative immunity exists so that lawmakers can make difficult and controversial decisions without fear of being personally sued. That concern applies at every level of government—from Congress all the way down to city councils.
The Court emphasized that what matters is the nature of the act itself, not the official’s intent.
In this case, voting to eliminate a department reflected a discretionary, policy-making decision, involved the city’s budget priorities, affected how services would be delivered to the public, and had consequences beyond just one individual.
Because of that, the Court held that the decision was quote “quintessentially legislative.”
So once again, even though someone may have been harmed, the officials involved were protected by absolute immunity—because of the function they were performing.
And now, let’s talk about absolute immunity for the President of the United States.
A key case here is the U.S. Supreme Court’s unanimous decision in Clinton v. Jones in 1997.
In that case, Paula Jones sued President Bill Clinton under Section 1983, seeking damages for alleged sexual harassment that occurred before he became president, while he was still Governor of Arkansas.
Clinton argued that as sitting President he should be immune from the lawsuit while in office.
The Supreme Court said no — a sitting President does not have absolute immunity from civil lawsuits for conduct that occurred before assuming office.
The Court explained that there is no constitutional rule that shields a President from civil litigation for unofficial conduct just because he is in office.
But, when a President is acting in an official capacity, carrying out core functions of the office, he is protected from personal liability for civil damages.
The bottom line is this:
Prosecutors, judges, legislators — and even Presidents —receive absolute immunity in narrow circumstances, tied to specific functions.
ICE agents are not on that list. They do not have absolute immunity.
So the next question is:
If they don’t have absolute immunity, what do they have?
The answer is something called qualified immunity.
Like absolute immunity, qualified immunity is not written into any statute.
There is no law on the books that created it.
It is a doctrine created by the courts.
Under qualified immunity, a government official can only be held personally liable for violating someone’s constitutional rights if a court has already ruled that the exact same conduct was unconstitutional in a prior case.
The legal phrase is that the right must be quote “clearly established.”
And here’s what that means in real life:
If there is no earlier case, with closely matching facts, saying this specific action was unconstitutional, the government official is immune.
So in theory, accountability is possible.
In practice, it is often nearly impossible.
That’s why members of Congress, judges, and legal scholars across the political spectrum have repeatedly called for reform or elimination of qualified immunity.
Judges themselves have written opinions saying they were deeply troubled by having to dismiss cases — not because the conduct was acceptable, but because the doctrine required it.
And that’s why this matters so much here.
Qualified immunity will very likely be a major obstacle for Renée Good’s family if they attempt to bring a civil rights lawsuit against the ICE agent under Section 1983.
But there is one important distinction:
Qualified immunity only limits private civil lawsuits. It does not prevent the state or federal government from taking action against an officer.
So if qualified immunity makes civil lawsuits nearly impossible, the next question is:
What about criminal accountability?
We’ve seen that it can happen.
Renée Good was killed about one mile from where George Floyd was murdered by a Minneapolis police officer on May 25, 2020.
And after George Floyd was murdered, the federal government did step in.
The Department of Justice brought federal criminal civil rights charges against the officers involved. After a nearly five-week federal trial, a jury found three former Minneapolis police officers guilty of civil rights violations arising from Mr. Floyd’s death.
Two of the officers were convicted for willfully failing to intervene while Derek Chauvin used unreasonable force. They were also convicted for being deliberately indifferent to Mr. Floyd’s serious medical needs while he was restrained and clearly in distress.
Both convictions were under Title 18, United States Code, Section 242 — a federal criminal civil rights statute that makes it a crime for a government official to willfully violate a person’s constitutional rights.
In December 2021, Derek Chauvin himself pleaded guilty in federal court to violating that same statute. In his plea, he admitted that he willfully deprived George Floyd of his constitutional right to be free from unreasonable force, resulting in bodily injury and death. He also agreed that his sentence should be based on second-degree murder, because he acted in callous and wanton disregard for Mr. Floyd’s life.
So what’s different here?
The investigation.
In the George Floyd case, there was a full federal investigation — conducted by the FBI, in cooperation with the Minnesota Bureau of Criminal Apprehension.
That investigation made prosecution possible.
But in the case of Renee Good, there has been no federal criminal civil rights investigation — and no joint federal-state effort to determine what happened.
And that leads to the next question:
If the federal government will not act, can the state of Minnesota?
And the answer depends on yet another doctrine of immunity, something called supremacy clause immunity.
Here’s the short version:
States can prosecute federal officials for state crimes, but only within limits.
Those limits come from the constitutional principle that states cannot undermine federal policy through targeted criminal prosecutions of federal officers. That principle is known as supremacy clause immunity.
But this protection is not absolute.
It only applies when a federal official is reasonably acting within the scope of lawful federal duties.
If a federal official acts outside those duties, violates federal law, or behaves in an egregious or unjustified way, a state prosecution can move forward.
Even when cases are later dismissed, states have at times used prosecutions to push back against federal actions they believe crossed the line.
So if this shooting had been carried out by a Minnesota police officer — like in the George Floyd case — the state could prosecute without any of these added layers.
But here, the federal government is saying there is nothing to investigate.
And without an investigation, nothing can be proven or disproven, especially under the criminal standard of beyond a reasonable doubt.
To bring criminal charges, Minnesota would need the full evidentiary record: forensic examinations, ballistics, medical examiner reports, body and vehicle inspections, medical records of the ICE agent, and complete eyewitness statements.
Right now, the public has only fragments — clips of video from different angles, partial timelines, and competing interpretations.
That’s not enough.
And that’s exactly why a federal investigation matters.
When federal authorities investigate, their job is not to secure a conviction. Their job is to find the truth, wherever it leads.
Here, a woman is dead. She was killed by a federal law enforcement officer.
That alone warrants full transparency and a complete factual record.
But instead, senior federal officials are saying there is no basis even to investigate.
So, is there any other path forward for Renée Good’s family?
There is one potential path forward.
Renée Good’s family could sue the United States government itself under a law called the Federal Tort Claims Act.
This would not be a lawsuit against the ICE agent personally. It would be a claim against the federal government for the acts of its employee.
It’s a difficult road, especially because there has not been an investigation.
And there is very recent precedent.
On April 14, 2021, the Department of Justice announced that it would not pursue criminal charges against the U.S. Capitol Police officer who fatally shot Ashli Babbitt on January 6, 2021.
The DOJ explained that it had conducted a thorough investigation. Officials reviewed video footage, witness statements, physical evidence, and autopsy results. After that review, prosecutors concluded there was insufficient evidence to prove, beyond a reasonable doubt, that the officer had willfully violated federal criminal civil rights law.
That law—18 United States Code § 242—is the same statute used in the George Floyd prosecutions.
And here’s the key legal point: To bring criminal charges under that statute, prosecutors must prove not only that force was unreasonable, but that the officer acted willfully—with a bad purpose to disregard the law.
Fear, panic, mistake, misperception, negligence, or even poor judgment are not sufficient.
Because prosecutors concluded they could not meet that standard, the criminal investigation was closed.
But the story didn’t end there.
Despite the decision not to pursue criminal charges, Ashli Babbitt’s estate and her husband filed a civil lawsuit against the United States under the Federal Tort Claims Act.
They alleged that her death was caused by the negligent or wrongful acts of a federal employee acting within the scope of his duties.
The estate initially sought $30 million.
And in June 2025, the United States settled the case for $4.975 million.
I’ve given you a lot today. It may not be enough—but I hope it’s more than you had before.
Here’s where things stand:
That leaves the Federal Tort Claims Act as a possible—though uncertain—path forward.
This administration may choose not to settle. A future administration might.
Ashli Babbitt died in January 2021. Her lawsuit wasn’t filed until January 2024. And it wasn’t resolved until June 2025.
When anyone dies—whether Renée Good or Ashli Babbitt—it is a tragedy. But tragedy without truth leaves families without answers.
We need to understand what happened. We need transparency. We need an investigation. Because Renée Good’s family deserves answers.
And so do we.
To return once more to the words of Martin Luther King, Jr., spoken on the eve of his death:
The nation is sick. Trouble is in the land. Confusion all around. But only when it is dark enough can you see the stars.
Let yourself be the star. Let your knowledge be the star.
You are amazing.
Thanks for listening today.
This is Death Readiness, real, messy and yours to own. I’m Jill Mastroianni and I’m here to help you sort through it, especially when you don’t know where to start.
Hi, I'm April, Jill's daughter. Thanks for listening to The Death Readiness Podcast. While my mom is an attorney, she’s not your attorney. The Death Readiness Podcast is for educational and entertainment purposes only. It does not provide legal advice. For legal guidance tailored to your unique situation, consult with a licensed attorney in your state. To learn more about the services my mom offers, visit DeathReadiness.com.