Procunier v. Navarette
Annotate this Case
434 U.S. 555 (1978)
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U.S. Supreme Court
Procunier v. Navarette, 434 U.S. 555 (1978)
Procunier v. Navarette
Argued October 11, 1977
Decided February 22, 1978
434 U.S. 555
Respondent state prisoner brought an action pursuant to 42 U.S.C. § 1983 against petitioner prison officials, alleging, inter alia, negligent interference with respondent's outgoing mail in violation of his constitutional rights under the First and Fourteenth Amendments. The District Court granted summary judgment for petitioners on this claim on the basis of their asserted qualified immunity from liability for damages under § 1983. The Court of Appeals reversed, holding that prisoners are entitled to First and Fourteenth Amendment protection for their outgoing mail, that the claim in question stated a cause of action under § 1983, and that summary judgment for petitioners was improper because, viewing the evidence in the light most favorable to respondent, petitioners were not entitled to prevail as a matter of law.
Held: The Court of Appeals erred in reversing the District Court's summary judgment for petitioners. Pp. 434 U. S. 560-566.
(a) Petitioners, as state prison officials, were entitled to immunity unless they "knew or reasonably should have known" that the action they took with respect to respondent's mail would violate his federal constitutional rights, or they took the action with the "malicious intention" to cause a deprivation of constitutional rights or other injury to respondent.
(b) There was no established First and Fourteenth Amendment right protecting state prisoners' mail privileges at the time in question, and therefore, as a matter of law, there was no basis for rejecting the immunity defense on the ground that petitioners knew or should have known that their alleged conduct violated a constitutional right. Pp. 434 U. S. 562-565.
(c) Neither should petitioners' immunity defense be overruled under the standard authorizing liability where the defendant state official has acted with "malicious intention" to deprive the plaintiff of a constitutional right or to cause him "other injury," since the claim in question charged negligent conduct, not intentional injury. P. 434 U. S. 566.
536 F.2d 277, reversed.
WHITE, J., delivered the opinion of the Court, in which BRENNAN, STEWART, MARSHALL, BLACKMUN, POWELL, and REHNQUIST, JJ., joined. BURGER, C.J., post, p. 434 U. S. 566, and STEVENS, J., post, p. 434 U. S. 568, filed dissenting opinions.