LUGAR v. EDMONDSON OIL CO.

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Case Basics
Docket No. 
80-1730
Petitioner 
Giles M. Lugar
Respondent 
Edmondson Oil Co.
Advocates
(on behalf of the Petitioner)
(on behalf of the Respondent)
Tags
Term:
Location: A truck stop
Facts of the Case 

Giles Lugar leased a truckstop from Edmondson Oil Co. and fell behind on his rent payments. Edmondson issued a suit against him in a Virginia state court for failing to repay his debt. Before the court reached a decision, it issued a "writ of attachment" against Lugar. This disabled him from selling any property he owned while the case was open, since Edmondson wanted the property as collateral in case he could not repay his debt. A state trial judge cancelled the "writ of attachment" one month later after finding no statutory justification for its issuance. Lugar claimed that Edmondson worked with the government to deprive him of his property without the due process of law guaranteed by the Fourteenth Amendment. He said this caused him financial loss and sought to recover damages from Edmondson in a District Court under 42 U.S.C. Section 1983. This code provides rewards to those who have had their rights violated because of "state action." The District Court rejected Lugar's claim because it deemed that no "state action" had occurred. On review, the United States Court of Appeals for the Fourth Circuit rejected using solely "state action" to validate Section 1983 suits. It claimed that certain instances where private parties acted "under the color of state law" also validated Section 1983 suits. However the Fourth Circuit found that none of these actions occurred in Lugar's case and rejected his suit.

Question 

Do "state actions" that occur indirectly "under the color of state law" and violate an individual's Fourtheenth Amendment rights validate damage recovery suits filed under 42 U.S.C. Section 1983?

Conclusion 
Decision: 5 votes for Lugar, 4 vote(s) against
Legal provision: Reconstruction Civil Rights Acts (42 USC 1983)

Yes. Justice Byron R. White delivered the opinion for a 5-4 court. The Fourteenth Amendment prevents "state actions" from intruding unlawfully upon the rights of citizens. Section 1983 offers relief to those who have their rights unlawfully abridged by actions occurring "under the color of state law." The Court decided that a state was liable for damages caused by unconstitutional conduct when two conditions were met. First, "the deprivation [of a constitutional right] must be caused by the exercise of some right or privilege created by the State." Second, "the party charged with the deprivation must be a person who may fairly be said to be a state actor." This includes both state officials and those whom are significantly aided by them. The Court previously found that the states guaranteed the due process of law when placing holds on disputed pieces of property, and therefore they are responsible for violations of this process. Accordingly, when Edmondson used state mechanisms to unconstitutionally deprive Lugar of his property, the state was responsible for compensating him for damages.

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LUGAR v. EDMONDSON OIL CO.. The Oyez Project at IIT Chicago-Kent College of Law. 20 July 2014. <http://www.oyez.org/cases/1980-1989/1981/1981_80_1730>.
LUGAR v. EDMONDSON OIL CO., The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/1980-1989/1981/1981_80_1730 (last visited July 20, 2014).
"LUGAR v. EDMONDSON OIL CO.," The Oyez Project at IIT Chicago-Kent College of Law, accessed July 20, 2014, http://www.oyez.org/cases/1980-1989/1981/1981_80_1730.