Thank You For Submiting Feedback!
42 U.S.C.S. § 1983 affords a "civil remedy" for deprivations of federally protected rights caused by persons acting under color of state law without any express requirement of a particular state of mind. Accordingly, in any 42 U.S.C.S. § 1983 action the initial inquiry must focus on whether the two essential elements to a 42 U.S.C.S. § 1983 action are present: (1) whether the conduct complained of was committed by a person acting under color of state law; and (2) whether this conduct deprived a person of rights, privileges, or immunities secured by the Constitution or laws of the United States.
Taylor, an inmate of a Nebraska prison, ordered by mail certain hobby materials. After being delivered to the prison, the packages containing the materials were lost when the normal procedure for receipt of mail packages was not followed. Taylor brought an action in Federal District Court under 42 U. S. C. § 1983 against petitioner prison officials to recover the value of the hobby materials, claiming that petitioners had negligently lost the materials and thereby deprived Taylor of property without due process of law in violation of the Fourteenth Amendment. The District Court entered summary judgment for Taylor, holding that negligent actions by state officials can be a basis for an action under § 1983, that petitioners were not immune from liability, and that the deprivation of the hobby materials implicated due process rights. The Court of Appeals affirmed.
Did Taylor’s claim arising from negligent loss of property by prison officials allege violation of Fourteenth Amendment's due process clause for purposes of stating claim for relief under 42 USCS 1983?
The Court reversed the lower appellate court decision that allowed Taylor’s civil right's claim for deprivation of property. The Court held that the act for which Taylor sought to recover was committed under the color of state law. The Court further held, however, that Taylor was not deprived of rights guaranteed under U.S. Const. amend. XIV because his deprivation did not result from established state procedure. Moreover, the Court found that post-deprivation procedures existed under state law. As a result, the Court held that a violation of Taylor’s constitutional rights did not occur. Therefore, the Court reversed the lower appellate court's finding that allowed the civil right's claim, and the claim was dismissed.