474 U.S. 327 (1986)
Roy Daniels was an inmate at the city jail in Richmond, Virginia.1 While there, he slipped on a pillow that respondent, a correctional deputy stationed at the jail, had left on the prison stairway.2 The fall caused Daniels to sustain back and ankle injuries.3
Daniels filed a suit under 42 U.S.C. § 1983 against the deputy.4 He alleged that the deputy's conduct had caused him injury and that the deputy would rely on sovereign immunity as a defense if Daniels pursued a state tort action instead.56
The District Court granted the deputy's motion for summary judgment.7 A panel of the Court of Appeals for the Fourth Circuit affirmed that judgment.8 On rehearing, the en banc Court of Appeals again affirmed the District Court's judgment, although it employed different reasoning from the panel.9
Because lower courts had taken inconsistent approaches to determining when tortious conduct by state officials rises to the level of a constitutional violation, the Supreme Court granted certiorari.10
Whether a negligent act by a state prison official causing unintended injury to an inmate constitutes a deprivation of liberty under the Due Process Clause of the Fourteenth Amendment?11
The Due Process Clause is simply not implicated by a negligent act of an official causing unintended loss of or injury to life, liberty, or property.12
No. Roy Daniels was an inmate at the city jail in Richmond, Virginia. While there, he slipped on a pillow that respondent, a correctional deputy stationed at the jail, had left on the prison stairway. The fall caused Daniels to sustain back and ankle injuries.13
Daniels filed a suit under 42 U.S.C. § 1983 against the deputy. He alleged that the deputy's conduct had caused him injury and that the deputy would rely on sovereign immunity as a defense if Daniels pursued a state tort action instead.
The District Court granted the deputy's motion for summary judgment. A panel of the Court of Appeals for the Fourth Circuit affirmed that judgment. On rehearing, the en banc Court of Appeals again affirmed the District Court's judgment, although it employed different reasoning from the panel.
Because lower courts had taken inconsistent approaches to determining when tortious conduct by state officials rises to the level of a constitutional violation, the Supreme Court granted certiorari. The facts establish only negligent conduct by the deputy in leaving the pillow on the stairs, and the rule requires more than lack of due care to trigger the Due Process Clause.14
A negligent act by a state prison official does not constitute a deprivation of liberty under the Due Process Clause.15
Related opinions on this issue
Justice Stevens concurred in the judgment. He agreed with the majority that petitioners cannot prevail under § 1983.16 He did not agree that it was necessary to redefine the meaning of deprive in the Fourteenth Amendment or to repudiate the reasoning of Parratt v. Taylor to support this conclusion.17
Stevens would apply Parratt directly to the procedural due process claim and hold that adequate state remedies defeat any § 1983 action because the state procedures are not fundamentally unfair.18
Whether the possibility that a state official may assert sovereign immunity as a defense renders a state tort remedy inadequate for purposes of a claim under 42 U.S.C. § 1983?19
The court need not decide whether the possibility of a sovereign immunity defense renders a state tort remedy inadequate under Parratt and Hudson v. Palmer.20
No. The claim fails because no deprivation occurred under the Due Process Clause, so the adequacy of any postdeprivation state remedy is never reached.21 The facts show Daniels alleged the deputy would assert sovereign immunity in a Virginia tort suit, yet the constitutional analysis ends before that question arises.22
The court does not reach whether sovereign immunity renders the state remedy inadequate.23
Related opinions on this issue
Justice Stevens addressed the sovereign immunity question in his concurrence. He concluded that a state's decision to afford its agents a sovereign immunity defense does not by itself render the remedial system constitutionally inadequate or fundamentally unfair under the Due Process Clause.24 Stevens noted that defenses such as sovereign immunity may defeat recovery in cases involving claims by prisoners against state employees without raising any question about the constitutionality of a State's procedures for disposing of tort litigation.25
He explained that those aspects of a State's tort regime that defeat recovery are not constitutionally invalid so long as there is no fundamental unfairness in their operation.26 Stevens emphasized that there is no reason to believe that the Due Process Clause of the Fourteenth Amendment should be construed to suggest that the doctrine of sovereign immunity renders a state procedure fundamentally unfair.27 In his view, the mere fact that a State elects to provide some of its agents with a sovereign immunity defense in cases involving prisoner claims does not justify the conclusion that its remedial system is constitutionally inadequate.
Whether inconsistent lower court approaches to when tortious conduct by state officials amounts to a constitutional violation require clarification from the Supreme Court?28
The Supreme Court grants certiorari when lower courts have taken inconsistent approaches to determining when tortious conduct by state officials rises to the level of a constitutional violation.29
Yes. Lower courts had reached varying conclusions on the constitutional status of negligent conduct by officials. This inconsistency among the circuits and the apparent lack of adequate guidance from the Court prompted the grant of certiorari to resolve the conflict and clarify that negligence alone does not implicate the Due Process Clause.30
Inconsistent lower court approaches required Supreme Court clarification.31