acts where personal jurisdiction is lacking, judicial and pros-ecutorial absolute immunity remain intact. See id. at 355-56. The district court ruling leaves unresolved, however, whether Brush, as a social worker, could claim prosecutorial immunity for her particular actions in this case. Her immunity was not addressed by Holloway apart from the preceding, and unavailing, contention regarding jurisdiction. Rather, Holloway attacked for the first time in her reply brief Brush’s claim that she had immunity because she was involved' in prosecution. The question thus arises as to whether that issue has been waived and is not reviewable on appeal. See United States v. Washington, 127 F.3d 510, 513 (6th Cir.1997) (citing United States v. Perkins, 994 F.2d 1184, 1191 (6th Cir.1993)) (<HOLDING>). The doctrine of Washington and Perkins is
holding that issues raised for the first time in a reply brief are not reviewable holding that an argument raised for the first time in a reply brief is waived holding argument is waived when raised for first time in reply brief holding that arguments raised for the first time in a reply brief are forfeited holding that issue raised for the first time in reply brief was waived