Richardson v. McKnight

Facts of the Case

Respondent McKnight, a prisoner at a Tennessee correctional center whose management had been privatized, brought a Federal District Court suit under 42 USCS 1983 against petitioners, privately employed prison guards, alleging that their physical restraint of him violated his civil rights. The district court denied petitioners’ motion to dismiss because of qualified immunity, holding that because the guards worked for a private company rather than the government, the law did not grant the guards immunity from suit. On interlocutory appeal, the United States Court of Appeals for the Sixth Circuit affirmed on similar grounds. Petitioners challenged the decision.

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.

Case Information

  • Citation: 521 US 399 (1997)
  • Argued: Mar 19, 1997
  • Decided Jun 23, 1997