The Oyez Project: Civil Rights Issues - Liability Decisions

Albright v. Oliver

Can a citizen prosecuted without probable cause obtain relief under 42 U.S.C. 1983 for the deprivation of substantive due process rights?

No. The Court ruled that Section 1983 relief for prosecution without probable cause is only valid if the prosecuted party claims Fourth Amendment (pretrial rights) violations. In a 7-2 decision authored by Chief Justice William Rehnquist, the Courtt reaffirmed its commitment not to extend substantive due process indefinitely and held that substantive due process does not guarantee non-interference by criminal investigations.

Allen v. Mccurry

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Baker v. Mccollan

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Brandon v. Holt

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Briscoe v. Lahue

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Bryan County, Oklahoma v. Brown

May municipalities be held liable for hiring employees who injure someone?

No. In a 5-4 decision, authored by Justice Sandra Day O'Connor, the Court ruled that municipalities are not liable for hiring employees who violate someone's rights unless a reasonable policymaker would conclude that the "plainly obvious consequence . . . would be the deprivation of a third party's federally protected rights. Thus, the county was not financially liable for Sheriff Moore's isolated decision to hire Burns without adequate screening because Brown had not proved that the decision reflected a conscious disregard for a risk that Burns would use excessive force in violation of her federally protected rights.

Buckley v. Fitzsimmons

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Burnett v. Grattan

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Burns v. Reed

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Canton v. Harris

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Carey v. Piphus

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Carpenters v. Scott

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Chardon v. Fumero Soto

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City of Rancho Palos Verdes v. Abrams

May people whose rights guaranteed by the Telecommunications Act of 1996 are violated seek remedies other than those allowed by the act?

No. In a 9-0 opinion delivered by Justice Antonin Scalia, the Court held that Abrams could not enforce the limitations of the Telecommunications Act on local authorities through federal liability law, because the act provides its own judicial remedy. Congress could not have meant the judicial remedy expressly authorized by the Telecommunications Act to co-exist with an alternative remedy.

Collins v. City Of Harker Heights, Texas

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Correctional Services Corp. v. Malesko

Should the implied private action for damages against federal officers alleged to have violated a citizen's constitutional rights, first recognized in Bivens v. Six Unknown Fed. Narcotics Agents, 403 U.S. 388, be extended to allow recovery against a private corporation operating a halfway house under contract with the Bureau of Prisons?

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that Bivens' limited holding may not be extended to confer a right of action for damages against private entities acting under color of federal law. The Court reasoned that the threat of suit against an individual's employer was not the kind of deterrence contemplated by the Bivens decision. The Court also noted that the purpose of the Bivens decision was to deter individual federal officers from committing constitutional violations. "In 30 years of Bivens jurisprudence we have extended its holding only twice, to provide an otherwise nonexistent cause of action against individual officers alleged to have acted unconstitutionally, or to provide a cause of action for a plaintiff who lacked any alternative remedy for harms caused by an individual officer's unconstitutional conduct. Where such circumstances are not present, we have consistently rejected invitations to extend Bivens,"wrote Chief Justice Rehnquist.

Crawford-El v. Britton

May lawsuits invoking 42 USC section 1983 to allege that a public official violated a prisoner's rights because of an unlawful motive be dismissed because the plaintiff fails to produce clear and convincing evidence of the unlawful motive?

No. In a 5-4 opinion delivered by Justice John Paul Stevens, the Court held that the Court of Appeals erred in fashioning a heightened burden of proof for unconstitutional-motive cases against public officials. "Neither the text of [section 1983] or any other federal statute, nor the Federal Rules of Civil Procedure, provides any support for imposing the clear and convincing burden of proof on plaintiffs either at the summary judgment stage or in the trial itself," wrote Justice Stevens. In a dissent joined by Justice Sandra Day O'Connor, Chief Justice William H. Rehnquist argued that a government official was entitled to immunity from a motive-based tort suit if the official could proffer a legitimate reason and the plaintiff could not establish that the reason given was a pretext.

Daniels v. Williams

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Davidson v. Cannon

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Davis v. Scherer

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Dennis v. Higgins

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Dennis v. Sparks

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District Of Columbia v. Carter

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Domino's Pizza v. McDonald

May a person who is not a party to a contract but suffers personal injuries from its termination sue under 42 U.S.C. Section 1981, claiming that the contract was terminated because of race?

No. The Court ruled in a unanimous decision (Justice Alito not participating) that only an actual or would-be party to a contract may sue under Section 1981. Justice Antonin Scalia, writing for the Court, explained that if Section 1981 were not limited to the party to the contract, it "would become a strange remedial provision designed to fight racial animus in all of its noxious forms, but only if the animus and the hurt it produced were somehow connected to somebody's contract. We have never read the statute in this unbounded--or rather, peculiarly bounded--way."

Edwards v. Balisok

May prisoners invoke 42 USC Section 1983 to sue for monetary damages over procedures used to deprive them of good time credit toward early release?

No. In a unanimous decision delivered by Justice Antonin Scalia, the Court held that Balisok's "claim for declaratory relief and monetary damages, based on allegations of deceit and bias on the part of the decisionmaker that necessarily imply the invalidity of the punishment imposed, is not cognizable...."

Flagg Bros., Inc. v. Brooks

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Forrester v. White

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General Building Contractors Assn. v. Pa.

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Golden State Transit Corp. v. Los Angeles

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Gomez v. Toledo

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Goodman v. Lukens Steel Co.

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Graham v. Connor

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Griffin v. Breckenridge

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Haddle v. Garrison

May at-will employees sue their employers over firings allegedly carried out to retaliate for testimony against their employers?

Yes. In a unanimous decision, announced by Chief Justice William H. Rehnquist, the Court ruled that such interference may give rise to a claim for damages under the Civil Rights Act of 1871. "The kind of interference with at-will employment relations alleged here is merely a species of the traditional torts of intentional interference with contractual relations and intentional interference with prospective contractual relations," wrote Chief Justice Rehnquist.

Hafer v. Melo

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Hardin v. Straub

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Haring v. Prosise

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Heck v. Humphrey

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Hill v. McDonough

Is a prisoner's challenge to a particular form of execution - but not to the execution sentence itself - the practical equivalent of a federal habeas corpus petition and therefore barred if the prisoner has already sought habeas review?

No. In a unanimous decision authored by Justice Anthony Kennedy, the Supreme Court held that challenging the form of execution was fundamentally different from challenging the lawfulness of a conviction or sentence, the traditional purposes of a habeas corpus appeal. This finding was supported by the fact that Hill conceded other forms of execution would be constitutional, and that Florida state law does not require the particular form of execution at issue in this case. "Under these circumstances," Justice Kennedy wrote, "a grant of injunctive relief could not be seen as barring the execution of Hill's sentence."

Imbler v. Pachtman

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Jett v. Dallas Independent School Dist.

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Kalina v. Fletcher

Does the doctrine of absolute prosecutorial immunity protect a prosecutor for making false statements of fact in an affidavit supporting an application for an arrest warrant against a damages remedy under 42 USC section 1983?

No. In a unanimous opinion delivered by Justice John Paul Stevens, the Court held that section 1983 may create a damages remedy against a prosecutor for making false statements of fact in an affidavit supporting an application for an arrest warrant, since such conduct is not protected by the doctrine of absolute prosecutorial immunity. Noting that the Fourth Amendment requires that arrest warrants be based "upon probable cause, supported by Oath or affirmation," Justice Stevens wrote that," [e]ven when the person who makes the constitutionally required 'Oath or affirmation' is a lawyer, the only function that she performs in giving sworn testimony is that of a witness." Thus, section 1983 may, under some circumstances, provide a damages remedy against such a prosecutor.

Kolstad v. American Dental Association

Does an employer's conduct have to be "egregious" or "outrageous," independent of its state of mind, in order to sustain an award of punitive damages under Title II of the 1964 Civil Rights Act?

No. In a complicated split opinion, the Court held that if an employee can show their employer knowingly acted in violation of federal law then punitive damages may be sustained. The Court explained that the "malice" or "reckless indifference" standard applied to the relationship between employers and federal law, and is not a characterization of the severity threshold that the discrimination itself must meet. In other words, if an employer maliciously or recklessly violates a federal anti-discrimination law, regardless of the severity of their discriminatory acts, them punitive damages may be imposed. The Court remanded Kolstad's case for renewed consideration of her employer's state of mind during the alleged violations.

Kush v. Rutledge

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Leatherman v. Tarrant County Narcotics Intelligence And Coordination Unit

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Loeffler v. Frank

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Lugar v. Edmondson Oil Co.

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Maine v. Thiboutot

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Malley v. Briggs

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Martinez v. California

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Mcdonald v. West Branch

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McMillian v. Monroe County, Alabama

Is a county liable for constitutional violations committed by the county sheriff in matters of law enforcement?

No. In a 5-4 decision, the Supreme Court affirmed the lower courts. The opinion by Chief Justice William Rehnquist held that because the county had no authority to make law enforcement policy, Sheriff Tate as a policymaker represented the state rather than the county. According to the Alabama Constitution and the Alabama Code, the Court held, Alabama sheriffs "act for the State when exercising their law enforcement functions."

Memphis Community School Dist. v. Stachura

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Migra v. Warren City School Dist. Bd. Of Ed.

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Monell v. New York City Dept. Of Social Services

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Monroe v. Pape

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Moor v. County Of Alameda

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Muhammad v. Close

Does the U.S. Supreme Court's decision in Heck v. Humphrey (1994) require that prisoners who challenge prison disciplinary proceedings - but whose suits do not question their sentences' validity - first successfully challenge their sentences?

No. In a unanimous per curiam opinion, the Court ruled that prisoners - whose suits do not question their sentences - do not need to successfully challenge those sentences before challenging prison disciplinary proceedings. The Court rejected the argument that Heck necessarily requires successful sentence appeals before any challenges can be made to prison disciplinary proceedings. Muhammad's suit sought damages for prison disciplinary proceedings but in no way challenged his sentence.

Nelson v. Campbell

Is a prisoner's appeal of the proposed procedure for his execution functionally equivalent to a habeas corpus petition and therefore barred by Title 28, Section 2254 of U.S. Code?

No. In an opinion by Justice Sandra Day O'Connor, the Court ruled unanimously that Nelson's suit dealt only with the proposed method of execution, not with his conviction or sentence, and was therefore different from a habeas corpus appeal. Nelson had a right to challenge the necessity of the procedure for his execution using the same legal approach he would have used to challenge the conditions of his prison. However, the Court declined to rule on whether the execution would be constitutional if the district court found that cutting through was indeed necessary, leaving that question for a case in which necessity had already been determined.

Newport v. Fact Concerts, Inc.

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Newton v. Rumery

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Ngiraingas v. Sanchez

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Oklahoma City v. Tuttle

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Owen v. City Of Independence

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Owens v. Okure

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Parratt v. Taylor

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Paul v. Davis

Did the distribution of the flyer violate Davis's right to privacy and liberty under the Due Process Clause of the Fourteenth Amendment?

In a 5-to-3 decision, the Court held that Davis had not been deprived of any constitutional rights under the Due Process Clause. The Court also emphasized that constitutional privacy interests did not cover Davis's claims. The Court argued that the constitutional right to privacy was limited to matters relating to "marriage, procreation, contraception, family relationships, and child rearing and education." The publication of records of official acts, such as arrests, did not fall under the rubric of privacy rights.

Pembaur v. Cincinnati

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Pierson v. Ray

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Polk County v. Dodson

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Procunier v. Navarette

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Pulliam v. Allen

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Rendell-Baker v. Kohn

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Richardson v. McKnight

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

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.

Saint Francis College v. Al-Khazraji

Did 42 U.S.C. Section 1981 apply to Arab minorities?

Yes. The Court held that persons of Arabian ancestry were protected from racial discrimination under Section 1981. Writing for a unanimous Court, Justice Byron R. White maintained that section 1981 encompassed discrimination even among Caucasians. Justice White noted that history did not support the claim that Arabs and other present-day "Caucasians" were considered to be a single race for the purposes of section 1981. Justice William J. Brennan, Jr., in a separate concurrence, added that "Pernicious distinctions among individuals based solely on their ancestry are antithetical to the doctrine of equality upon which this nation is founded."

Schweiker v. Chilicky

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Shaare Tefila Congregation v. Cobb

Did the white defendants exhibit racially motivated discrimination in violation of the federal statute?

Yes. The Court unanimously ruled that Jews can state a claim of racial discrimination since they were among the peoples considered to be distinct races and hence within the protection of U.S.C. Section 1982. The statute "was intended to protect from discrimination identifiable classes of persons who are subjected to intentional discrimination solely because of their ancestry or ethnic characteristics." The Jewish people most certainly suffered such discrimination and so were not barred from their claim simply because both they, like the defendants, were Caucasian.

Smith v. Wade

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Springfield Township School Dist. v. Knoll

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Springfield v. Kibbe

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St. Louis v. Praprotnik

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Stump v. Sparkman

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Supreme Court Of Va. v. Consumers Union

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Tower v. Glover

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United States v. Guest

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United States v. Morrison

Does Congress have the authority to enact the Violence Against Women Act of 1994 under either the Commerce Clause or Fourteenth Amendment?

No. In a 5-4 opinion delivered by Chief Justice William H. Rehnquist, the Court held that Congress lacked the authority to enact a statute under the Commerce Clause or the Fourteenth Amendment since the statute did not regulate an activity that substantially affected interstate commerce nor did it redress harm caused by the state. Chief Justice Rehnquist wrote for the Court that [i]f the allegations here are true, no civilized system of justice could fail to provide [Brzonkala] a remedy for the conduct of...Morrison. But under our federal system that remedy must be provided by the Commonwealth of Virginia, and not by the United States." Dissenting, Justice Stephen G. Breyer argued that the majority opinion "illustrates the difficulty of finding a workable judicial Commerce Clause touchstone." Additionally, Justice David H. Souter, dissenting, noted that VAWA contained a "mountain of data assembled by Congress...showing the effects of violence against women on interstate commerce."

United States v. Price

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West v. Atkins

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West v. Gibson

Does the Equal Employment Opportunity Commission possess the legal authority to require federal agencies to pay compensatory damages when they discriminate in employment in violation of Title VII of the Civil Rights Act of 1964?

Yes. In a 5-4 opinion delivered by Justice Stephen G. Breyer, the Court held that the Equal Employment Opportunity Commission possess the legal authority to require federal agencies to pay compensatory damages when they discriminate in violation of Title VII of Civil Rights Act of 1964. Justice Anthony M. Kennedy, writing for the dissenting minority, expressed the view that that the EEOC could not have awarded compensatory damages against the United States under Title VII because the statute did not authorize such awards in explicit terms. Therefore, according to Justice Kennedy, it did not provide the required waiver of the United States' sovereign immunity.

Will v. Michigan Dept. Of State Police

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Wilson v. Garcia

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Wood v. Strickland

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Wyatt v. Cole

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Zinermon v. Burch

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