Chappell v. Wallace

Background

Five enlisted Navy men serving on a combat ship sued their commanding officer, four lieutenants, and three noncommissioned officers. They alleged race-based mistreatment: denial of desirable duties, threats, low performance evaluations, unusually severe penalties, and a conspiracy to deprive rights under the Constitution and 42 U.S.C. §1985. The federal district court dismissed the complaint as nonreviewable military decisions, found officers immune, and faulted the men for failing to exhaust administrative remedies. The Ninth Circuit reversed and applied tests to decide whether civilian courts could hear the claims.

Reasoning

The Court examined whether a Bivens-style federal money-damages remedy should be available and whether any “special factors counseling hesitation” existed. Relying on Feres and the special nature of military discipline, the opinion stressed the need for immediate obedience, the Framers’ allocation of military control to Congress, and the existence of internal military remedies. The Court pointed to Article 138 of the Uniform Code of Military Justice and the Board for Correction of Naval Records (10 U.S.C. §1552) as Congress-created channels for complaints. Because allowing civilian damage suits would disrupt command relationships and intrude on Congress’s primary authority over the armed forces, the Court held that those special factors make a damages remedy inappropriate for enlisted personnel suing superior officers.

Real world impact

Enlisted service members cannot recover money damages from superior officers in civilian court for constitutional wrongs arising during military service. Claims like these must be pursued through military procedures or legislative action. The Court reversed the Ninth Circuit and remanded for further proceedings, leaving the §1985 conspiracy question for the lower courts.