Facts of the Case

Ronnie Lee McKnight, a prisoner at Tennessee's South Central Correctional Center (SCCC), filed suit, under 42 USC section 1983, against two prison guards after he was placed in extremely tight physical restraints. Previously, the SCCC's management had been privatized by the State. Ultimately, the prison guards, Darryl Richardson and John Walker, asserted a qualified immunity and moved to dismiss the action. The District Court denied the motion, finding that, since a private prison management firm employed them, they were not entitled to qualified immunity. The Court of Appeals affirmed.

Question

Are prison guards, who are employees of a private prison management firm, entitled to a qualified immunity from suit under 42 USC section 1983?

Conclusion

No. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that prison guards employed by a private firm are not entitled to a qualified immunity from suit by prisoners charging a section 1983 violation. Emphasizing that a private firm was systematically organized to manage the prison, Justice Breyer wrote that, "[o]ur examination of history and purpose...reveals nothing special enough about the job or about its organizational structure that would warrant providing these private prison guards with a governmental immunity." Dissenting, Justice Antonin Scalia argued that the Court had routinely determined section 1983 immunity on the basis of the public function being performed. Chief Justice William H. Rehnquist and Justices Anthony M. Kennedy and Clarence Thomas joined Justice Scalia.