Richardson v. McKnight


DOCKET NO.: 96-318
DECIDED BY: Rehnquist Court (1986-2005)
LOWER COURT: United States Court of Appeals for the Sixth Circuit

CITATION: 521 US 399 (1997)
ARGUED: Mar 19, 1997
DECIDED: Jun 23, 1997

Charles R. Ray – Argued the cause for the petitioners
David C. Vladeck – Argued the cause for the respondent
Edwin S. Kneedler – Argued the cause for the United States, as amicus curiae, by special leave of court, supporting the respondent

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.


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

Media for Richardson v. McKnight

Audio Transcription for Oral Argument – March 19, 1997 in Richardson v. McKnight

Audio Transcription for Opinion Announcement – June 23, 1997 in Richardson v. McKnight

The opinions of the Court in two cases will be announced by Justice Breyer.

In Richardson versus McKnight and the Civil Rights Actions that are brought under 42 U.S.C Section 1983, employees of the State including guards at state prisons run by the State ordinarily are entitled to a qualified immunity.

This case asks whether prison guards employed in a privatized state prison system, a system in which they work for a private firm that runs the prison are also entitled to a similar immunity.

We hold that they are not.

Our reasons are of two sorts.

The first is historical.

Our look into the historical records suggests that guards at privatized state prisons, forms of which did exist in the 19th century, were subject to suit in roughly comparable cases.

The second sort of reason is policy-based.

We examine the reasons why immunity has been granted government employees and we conclude that some important reasons are not present here or present only to a significantly diminished degree.

These are the matters we go into in our opinion.

We do not decide whether the defendants here would be liable under Section 1983, nor do we decide whether they might be able to assert various other special defenses such as a good faith defense.

We hold only that they cannot assert a defensive qualified immunity and we therefore affirm the similar determination of the Sixth Circuit.

Justice Scalia has filed a dissenting opinion in which the Chief Justice, Justice Kennedy and Justice Thomas have joined.