In Bogan v. Scott-Harris, 523 U.S. 44 (1998), the United States Supreme Court held that local legislators are absolutely immune from suit under 1983 for their legislative activities. The Court held that absolute immunity attaches to all action taken in the sphere of legitimate legislative activity, which is to be determined by the nature of the act. Id. at 54-5. Officials outside the legislative branch are entitled to legislative immunity when they perform legislative functions. Id. at 55. The Court held that Bogan's acts, including the introduction of a budget and signing into law an ordinance, were formally legislative, even though he was an executive official, because they constituted "integral steps in the legislative process." Id. Expanding on this rationale, the Court held: We need not determine whether the formally legislative character of petitioners' actions is alone sufficient to entitle petitioners to legislative immunity, because here the ordinance, in substance, bore all the hallmarks of traditional legislation. The ordinance reflected a discretionary, policymaking decision implicating the budgetary priorities of the city and the services the city provides to its constituents. Moreover, it involved the termination of a position, which, unlike the hiring or firing of a particular employee, may have prospective implications that reach well beyond the particular occupant of the office. And the city council, in eliminating DHHS, certainly governed "in a field where legislators traditionally have power to act." Id. at 56. In Bogan, the executive official was found liable because he prepared a budget proposal which eliminated 135 city positions, including that of the plaintiff in that case. 523 U.S. at 47.