Daniels v. Williams, 474 U.S. 327 (1986)
Due process is not implicated in negligent acts by state officials.
When a prison official acted carelessly, Daniels slipped and fell. He argued in federal court that the negligence of the official had infringed on his liberty interest in freedom from injury. This due process claim was rejected by the courts.Opinions
- William Hubbs Rehnquist (Author)
- Warren Earl Burger
- William Joseph Brennan, Jr.
- Byron Raymond White
- Lewis Franklin Powell, Jr.
- Sandra Day O'Connor
Deliberate violations of individual rights and government abuses of power are the appropriate areas for due process claims . Merely careless or negligent actions bring it too close to pre-existing tort doctrines under the common law and would improperly blend federal with state law.
- Thurgood Marshall (Author)
- Harry Andrew Blackmun (Author)
- John Paul Stevens (Author)
Due process should not alter the customary tort law regarding claims against government officials. The negligence of prison guards does not rise to the level of significance needed to hold the government accountable for arbitrary exercises of power. This decision thus shows that a seemingly sweeping clause has limits.
U.S. Supreme CourtDaniels v. Williams, 474 U.S. 327 (1986)
Daniels v. Williams
Argued November 6, 1985
Decided January 21, 1986
474 U.S. 327
Petitioner brought an action in Federal District Court under 42 U.S.C. § 1983, seeking to recover damages for injuries allegedly sustained when, while an inmate in a Richmond, Virginia, jail, he slipped on a pillow negligently left on a stairway by respondent sheriff's deputy. Petitioner contends that such negligence deprived him of his "liberty" interest in freedom from bodily injury "without due process of law" within the meaning of the Due Process Clause of the Fourteenth Amendment. The District Court granted respondent's motion for summary judgment, and the Court of Appeals affirmed.
Held: The Due Process Clause is not implicated by a state official's negligent act causing unintended loss of or injury to life, liberty, or property. Pp. 474 U. S. 329-336.
(a) The Due Process Clause was intended to secure an individual from an abuse of power by government officials. Far from an abuse of power, lack of due care, such as respondent's alleged negligence here, suggests no more than a failure to measure up to the conduct of a reasonable person. To hold that injury caused by such conduct is a deprivation within the meaning of the Due Process Clause would trivialize the centuries-old principle of due process of law. Parratt v. Taylor, 451 U. S. 527, overruled to the extent that it states otherwise. Pp. 474 U. S. 329-332.
(b) The Constitution does not purport to supplant traditional tort law in laying down rules of conduct to regulate liability for injuries that attend living together in society. While the Due Process Clause speaks to some facets of the relationship between jailers and inmates, its protections are not triggered by lack of due care by the jailers. Jailers may owe a special duty of care under state tort law to those in their custody, but the Due Process Clause does not embrace such a tort law concept. Pp. 474 U.S. 332-336.
748 F.2d 229, affirmed.
REHNQUIST, J., delivered the opinion of the Court, in which BURGER, C.J., and BRENNAN, WHITE, POWELL, and O'CONNOR, JJ., joined. MARSHALL, J., concurred in the result. BLACKMUN, J., post, p. 474 U. S. 336, and STEVENS, J., post, p. 474 U. S. 336, filed opinions concurring in the judgment.