Parratt v. Taylor

Supreme Court of the United States · 1981 · Administrative Law

Administrative LawFederal CourtsSection 1983Procedural Due Process42 U.S.C. § 1983Fourteenth Amendmentprocedural due processproperty deprivation

Facts

Taylor, an inmate at the Nebraska Penal and Correctional Complex, ordered hobby materials worth $23.50 through the mail. The packages arrived at the prison and were signed for by employees in the hobby center, but Taylor was in segregation and never received them. Prison procedures required delivery to the addressed prisoner or notice to pick up the package and sign a receipt, and no other inmate was supposed to sign for it. Taylor sued the prison warden and hobby manager under § 1983, alleging that their negligence caused a deprivation of property without due process, even though Nebraska had a tort claims procedure for losses caused by the State.

Issue

Whether a prisoner's claim that state prison officials negligently lost his property states a deprivation of property without due process of law under the Fourteenth Amendment, actionable under 42 U.S.C. § 1983, when the loss resulted from a random and unauthorized failure to follow established state procedure and the State provides an adequate postdeprivation tort remedy.

Rule

In a § 1983 action, the initial inquiry is whether the conduct was committed by a person acting under color of state law and whether that conduct deprived a person of a right secured by the Constitution or laws of the United States. When a property loss is caused by a random and unauthorized act of a state employee rather than by an established state procedure, and it is impracticable or impossible for the State to provide a meaningful predeprivation hearing, the requirements of procedural due process are satisfied by an adequate postdeprivation remedy provided by the State.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

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

In Columbus, Ohio, Dana Ruiz stored her camera in a locker at a state-run museum while attending a public workshop. A museum employee accidentally gave the camera to another visitor contrary to museum rules, and Ohio law provides a claims procedure through which Dana can recover the camera's value from the State.

If Dana sues the employee in federal court under § 1983 alleging deprivation of property without due process, which issue should the court address first under the governing framework?

Explanation. The majority states that in any § 1983 action, the initial inquiry has two elements: whether the challenged conduct was committed by a person acting under color of state law, and whether that conduct deprived the plaintiff of a right secured by the Constitution or laws of the United States. The availability of punitive damages, jury trial, or a diversity amount is not the first inquiry, and the Court did not make intent a threshold requirement for all § 1983 claims.