Crawford-El v. Britton - 523 U.S. 574, 118 S. Ct. 1584 (1998)

Rule:

Neither the text of 42 U.S.C.S. § 1983 or any other federal statute, nor the Federal Rules of Civil Procedure, provides any support for imposing the clear and convincing burden of proof on plaintiffs either at the summary judgment stage or in the trial itself.

Facts:

Petitioner Leonard Rollon Crawford-El was a litigious and outspoken prisoner in the District of Columbia's correctional system. Because of overcrowding at the District's prison, he was transferred, first to Washington State, then to facilities in several other locations, and ultimately to Florida. His belongings were transferred separately. When the District's Department of Corrections received his belongings from Washington State, respondent, a District correctional officer, had petitioner's brother-in-law pick them up, rather than shipping them directly to petitioner's next destination. Petitioner did not recover the belongings until several months after he reached Florida. Subsequently, petitioner filed suit under 42 U.S.C. § 1983, alleging, inter alia, that respondent's diversion of his property was motivated by an intent to retaliate against him for exercising his First Amendment rights. The District Court dismissed the complaint. In remanding, the en banc Court of Appeals concluded, among other things, that in an unconstitutional-motive case, a plaintiff must establish motive by clear and convincing evidence, and that the reasoning in Harlow v. Fitzgerald, 457 U.S. 800, 73 L. Ed. 2d 396, 102 S. Ct. 2727, required special procedures to protect defendants from the costs of litigation. Certiorari was granted. 

Issue:

In an unconstitutional-motive case, must a plaintiff establish motive by clear and convincing evidence? 

Answer:

No.

Conclusion:

The United States Supreme Court rejected the rule imposed by the appellate court, differentiating between the qualified immunity, that required proof that a defendant knew or should have known that a plaintiff's constitutional rights were being violated, from the intent element that the new rule would have imposed on the plaintiff. The Court held that the law did not bar claims that depended on proof of an official's motive. Neither the text of 42 U.S.C.S. § 1983 nor other federal statutes provided any support for imposing the clear and convincing burden of proof of improper motive on plaintiffs either at the summary judgment state or in the trial itself. Furthermore, the Court found sufficient exiting safeguards available to trial courts in the management of the factfinding process that were more useful and equitable to all parties.