Supreme Court of the United States · 1986 · Federal Courts
Federal CourtsSection 1983Due Process ClausePrisoners' Rights42 U.S.C. § 1983Fourteenth AmendmentDue Processnegligence
Facts
Daniels alleged that while he was an inmate at the city jail in Richmond, Virginia, he slipped on a pillow left on a prison stairway by Williams, a correctional deputy. He claimed he suffered back and ankle injuries. Daniels argued that Williams' negligence deprived him of a liberty interest in freedom from bodily injury without due process of law. He also argued that he lacked an adequate state remedy because Williams asserted sovereign immunity in a possible state tort suit.
Issue
Does the negligent act of a state prison official that unintentionally causes bodily injury to an inmate constitute a deprivation of life, liberty, or property under the Due Process Clause of the Fourteenth Amendment, actionable under § 1983?
Rule
The Due Process Clause is not implicated by a merely negligent act of a state official causing unintended loss of or injury to life, liberty, or property. Mere lack of due care does not amount to a constitutional deprivation under the Fourteenth Amendment.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
At a county jail in Toledo, Ohio, Officer Nina Torres forgot to secure a mop bucket after cleaning a corridor. Inmate Caleb Morris slipped on the spilled water and fractured his wrist, then filed a § 1983 action alleging that the officer deprived him of liberty without due process of law.
How should the federal court rule on the due process claim?
Explanation. The majority held that the Due Process Clause is not implicated by a merely negligent act of a state official causing unintended loss of or injury to life, liberty, or property. Although § 1983 has no independent state-of-mind requirement, the plaintiff must still show violation of the underlying constitutional right, and negligence is insufficient for due process. The existence of custody does not convert ordinary carelessness into a constitutional deprivation. (Derived from Daniels v. Williams (n.d.).)