Daniels v. Williams Case Brief

Why is the case important?

Petitioner Daniels slipped on a pillow allegedly left on the stairs of the Richmond City Jail by Respondent Williams. Petitioner suffered back and ankle injuries from this fall. Petitioner claims that not allowing a suit for negligence, barred because of sovereign immunity, is a deprivation of his liberty under the Due Process Clause of the Fourteenth Amendment.

Facts of the case

Question

Is the Due Process Clause implicated by a negligent act of an official causing unintended loss of or injury to life, liberty or property?

Answer

No. Affirmed.
The Due Process Clause is not implicated by a negligent act of an official causing unintended loss of or injury to his life, liberty or property. The Due Process Clause was intended to secure the individual from the arbitrary exercise of the powers of government by promoting fairness in decisions involving life, liberty or property.
The action of prison custodians leaving a pillow on the stairs of the Richmond City Jail is remote from these concerns. Lack of due care suggests no more than a failure to measure up to the conduct of a reasonable person. The Due Process Clause is not meant to supplant traditional tort law in laying down rules of conduct to regulate liability for injuries.
The only tie in this case to anything governmental is the fact that Respondent was a sheriff’s deputy in the jail where Petitioner was an inmate. Where a government official’s act causing injury to life, liberty or property is merely negligent no procedure for compensation is constitutionally required.
The enactment of tort claim statutes reflects the view that such negligence should generally be redressed, but the negligent conduct does not give rise to a due process claim.
Concurrence. There are two concurrences, but no discussion.

Conclusion

“The United States Supreme Court found that Daniels’ action was properly dismissed because a prison official’s mere lack of due care did not constitute a deprivation of liberty under the Due Process Clause of the Fourteenth Amendment . The Court held, overruling in part Parratt v Taylor (1981) 451 US 527, 68 L Ed 2d 420, 101 S Ct 1908 , that the due process clause is not implicated by negligent acts of state officials which cause unintended loss or injury, as these do not “”deprive”” a person of life, liberty, or property under the Fourteenth Amendment .”

  • Case Brief: 1986
  • Petitioner: Daniels
  • Respondent: Williams
  • Decided by: Burger Court

Citation: 474 US 327 (1986)
Argued: Nov 6, 1985
Decided: Jan 21, 1986