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Logan v. Zimmerman Brush Co.

Supreme Court of the United States · 1982 · Constitutional Law

Constitutional LawDue ProcessProcedural Due ProcessProperty InterestsState-Created Causes of ActionFourteenth Amendmentdue processproperty interest

Facts

Illinois's Fair Employment Practices Act required a discrimination complainant to file a charge within 180 days and required the Commission to convene a factfinding conference within 120 days of filing. Logan timely filed a charge alleging that Zimmerman Brush Company fired him because of his physical handicap, but through Commission inadvertence the conference was scheduled five days after the 120-day deadline. When the conference date arrived, the employer moved to dismiss based on the missed deadline, and the Illinois Supreme Court held that the Commission's failure to meet the deadline deprived it of jurisdiction and terminated Logan's claim. Logan had no control over the Commission's scheduling error, and the Illinois court also barred his second charge based on the same alleged discrimination.

Issue

Whether the Fourteenth Amendment permits a State to terminate a complainant's state-created discrimination claim because a state agency, for reasons beyond the complainant's control, failed to comply with a statutory deadline for convening a factfinding conference. More specifically, the question is whether Logan's right to pursue the FEPA adjudicatory process was a protected property interest and, if so, what process was constitutionally required before that right could be extinguished.

Rule

A cause of action or state-created right to use adjudicatory procedures can be a property interest protected by the Due Process Clause. Once such an entitlement is conferred, the State may not, through an established state procedure, finally destroy it without providing the claimant an opportunity at a meaningful time and in a meaningful manner to present the merits of his claim; a postdeprivation tort remedy is not sufficient where the deprivation results from the state system itself rather than from a random and unauthorized act.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Ohio, a state statute gives tenants a right to file housing-discrimination complaints with the Fair Housing Review Board. If the Board finds substantial evidence, the case proceeds to a formal hearing and possible relief, but the statute says the Board must assign an investigator within 45 days or the complaint is dismissed. Nina Patel filed on time in Cleveland, but the Board failed to assign anyone until day 52, and her complaint was terminated automatically.

Nina argues that the automatic termination violated procedural due process. What is the strongest argument in her favor?

Explanation. The majority treated a state-created cause of action or right to invoke adjudicatory procedures as a protected property interest when state law guarantees redress subject to an evidentiary standard such as substantial evidence. Once conferred, that entitlement cannot be finally destroyed by an established state procedure without an opportunity to be heard on the merits. The Court did not hold that all statutory rights are fundamental, that negligence alone establishes a due process violation, or that all deadlines are invalid.