Parratt v. Taylor

Background

A man in a Nebraska prison ordered hobby materials worth $23.50. The packages arrived and were signed for in the prison hobby center, but the prisoner — then in segregation — never received them. He sued the prison warden and hobby manager in federal court under the federal civil-rights law, saying the loss deprived him of property without due process. The district court ruled for the prisoner and the Eighth Circuit affirmed, and the Supreme Court agreed to decide the legal question.

Reasoning

The Court asked whether a negligent, unauthorized loss of property by state employees violates the Fourteenth Amendment unless the State provides a hearing before the loss. The justices explained that pre-takings hearings are appropriate when taking is done under an established state procedure, but random or unauthorized acts cannot practically be checked beforehand. When the State offers an adequate postdeprivation remedy, the Court held, that procedure can satisfy due process. Nebraska had a tort-claims process for prisoners to recover losses. Because that postdeprivation remedy was available, the Court concluded the Fourteenth Amendment was not violated in this negligent-loss case and reversed the lower courts.

Real world impact

The decision limits federal civil-rights suits for ordinary negligence by state employees when state law provides a meaningful way to recover. It sends many small property-loss claims back to state tort or claims procedures. The ruling leaves open federal claims for intentional, systemic, or otherwise inadequately remedied deprivations.

Dissents or concurrances

Several justices agreed with parts of the ruling but differed on scope. One justice said negligent losses should never count as constitutional deprivations; another stressed that if prison officials failed to tell the inmate about state remedies, the state remedy might be inadequate and the federal claim should stand.