In Pitts v. County of Kern (1998) 17 Cal.4th 340, defendants in a criminal case brought a federal civil rights action against the district attorney and the county, alleging they engaged in misconduct during the criminal prosecution. (Id. at pp. 345-346.) In analyzing whether any absolute or qualified immunities applied to the district attorney's acts, the California Supreme Court noted, "The availability of immunity from liability under section 1983 in state court is governed by federal, not state, law." (Id. at p. 350.) The case was not an anti-SLAPP case and did not discuss the applicability of the anti-SLAPP statute to federal civil rights actions.