Summary
The Supreme Court held that negligent conduct by prison officials that results in injury from an attack by another inmate does not constitute a deprivation of liberty under the Fourteenth Amendment. Applying Daniels v. Williams, the Court concluded that the Due Process Clause does not require a compensation procedure for injuries caused by a state official's lack of due care. The judgment of the United States Court of Appeals for the Third Circuit was affirmed.
Topics
Practice areas
Questions Presented
- Whether prison officials' negligent failure to protect an inmate from an attack by another inmate constitutes a deprivation of liberty within the meaning of the Fourteenth Amendment.
- Whether the Due Process Clause requires a procedure or remedy for compensation when a government official's merely negligent conduct causes unintended injury to life, liberty, or property.
Holdings
- Merely negligent conduct by prison officials that causes unintended injury does not constitute a deprivation of liberty under the Fourteenth Amendment.
- The Fourteenth Amendment does not require a remedy when the challenged negligence does not constitute a constitutional deprivation.
Key quotations
“In other words, where a government official is merely negligent in causing the injury, no procedure for compensation is constitutionally required.” (347)
“The guarantee of due process has never been understood to mean that the State must guarantee due care on the part of its officials.” (348)
“As we held in Daniels, the protections of the Due Process Clause, whether procedural or substantive, are just not triggered by lack of due care by prison officials.” (348)
Factual background
While incarcerated at the New Jersey State Prison at Leesburg, Davidson was threatened by fellow inmate McMillian. Davidson reported the threat in writing, and prison officials received and understood the report but did not take protective measures; one official believed the situation was not urgent and another left the note unread and later forgot about it. Two days later, McMillian attacked Davidson with a fork, causing a broken nose and wounds to his face, neck, head, and body.
Procedural history
The District Court found no Eighth Amendment violation because the officials did not act with deliberate or callous indifference, but found a Fourteenth Amendment due process violation based on negligent failure to protect petitioner and awarded $2,000 in damages. The Third Circuit en banc reversed, holding that negligence did not constitute a constitutional deprivation. The Supreme Court affirmed, relying on Daniels v. Williams.