Law School Case Brief
Daniels v. Williams - 474 U.S. 327, 106 S. Ct. 662 (1986)
The Due Process Clause of the Fourteenth Amendment is not implicated by a negligent act of an official causing unintended loss of or injury to life, liberty, or property
Roy Daniels, an inmate in a local jail, who had supposedly slipped on a pillow negligently left on a stairway by a corrections officer, filed suit, in the United States District Court for the Eastern District of Virginia, for alleged violations of his constitutional rights, claiming that the officer had negligently deprived him of his liberty interest in freedom from bodily injury, and that this deprivation was without due process of law because the officer claimed that he would be entitled to a defense of sovereign immunity in a state tort action. The District Court granted the officer's motion for summary judgment. A panel of the United States Court of Appeals for the Fourth Circuit affirmed, finding that Daniels would not be deprived of a meaningful opportunity to present his case in state court even if the officer could make out a defense of sovereign immunity. On rehearing en banc, the Court of Appeals again affirmed, holding that the negligent infliction of bodily injury does not constitute a deprivation of any interest protected by the due process clause, and that Daniels had an adequate remedy in state court, since the ministerial nature of the officer's duties would have precluded him from successfutly defending on the ground of sovereign immunity.
Did a prison official's mere lack of due care constitute a deprivation of liberty under the Due Process Clause of the Fourteenth Amendment?
The United States Supreme Court found that Daniels’ action was properly dismissed because a prison official's mere lack of due care did not constitute a deprivation of liberty under the Due Process Clause of the Fourteenth Amendment. The Court held, overruling in part Parratt v Taylor (1981) 451 US 527, 68 L Ed 2d 420, 101 S Ct 1908, that the due process clause is not implicated by negligent acts of state officials which cause unintended loss or injury, as these do not "deprive" a person of life, liberty, or property under the Fourteenth Amendment.
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