Also known as: adequate causes · sufficient cause
Written by attorneys — see sources below.
A basis that meets the legal threshold for permitting an action or finding when supporting facts demonstrate the required causal link or hazard. The basis exists when the actor's conduct subjects another to the precise risk that later materializes as harm or when affidavits establish grounds for further proceedings.
Aaron Adams rolled through a stop sign at a blinking red light. An officer on a narcotics task force observed the violation from fifty yards away in daylight and pulled him over. The officer immediately asked for consent to search the car for drugs rather than issuing a citation. The stop rested on adequate cause because the observed traffic violation supplied an objective basis regardless of the officer's other investigative goals.
Anika Anand, a public employee, circulated a questionnaire criticizing office policies. Her supervisor fired her the next day citing the questionnaire. Adequate cause for the termination existed only if the speech did not address a matter of public concern. Otherwise the firing raised constitutional questions under the governing standard.
Sheila Myers worked as an Assistant District Attorney in the New Orleans office under District Attorney Harry Connick for approximately five and a half years. In early October 1980, Myers was informed she would be transferred to prosecute cases in a different section of the criminal court. She strongly opposed the transfer and expressed her objections to several supervisors including Connick. On October 6, 1980, Myers received formal notice of the transfer. Later that day she discussed her concerns with First Assistant District Attorney Dennis Waldron. That night Myers prepared a questionnaire soliciting the views of fellow Assistant District Attorneys on office transfer policy, office morale, the need for a grievance committee, the level of confidence in supervisors, and whether employees felt pressured to work in political campaigns. The next morning, she typed and copied the questionnaire. She then distributed it to fifteen Assistant District Attorneys. Connick learned of the distribution shortly after noon on October 7. He returned to the office, informed Myers she was being terminated for refusing the transfer, and stated that distributing the questionnaire constituted insubordination. Myers filed suit under 42 U.S.C. § 1983 alleging the termination violated her First Amendment rights. The District Court found the questionnaire was the real reason for discharge, submitted the motivating-factor question to a jury which answered in Myers' favor, and ordered reinstatement with backpay. The Court of Appeals for the Fifth Circuit affirmed, and the Supreme Court granted certiorari.
View caseAlfred Ashford, a state college instructor, received notice that his contract would not be renewed. He claimed a property interest in continued employment. Adequate cause for a hearing existed only if state law or university rules secured an entitlement to the position beyond a mere subjective expectancy.
In 1968 the Board of Regents of State Colleges hired David Roth as an assistant professor of political science at Wisconsin State University-Oshkosh for a fixed term running from September 1, 1968, to June 30, 1969. The formal notice of appointment stated that the employment basis was the academic year. It provided that regulations governing tenure followed Wisconsin Statutes Chapter 37.31. Roth was informed before he began teaching that he had no tenure rights and would be rehired for the 1969-1970 academic year only if the University chose to retain him. Under Wisconsin law a teacher could acquire tenure as a permanent employee only after four years of continuous service. The Board of Regents' rules established February 1 as the deadline for written notification of non-retention for nontenured faculty. No reason for non-retention need be given and no review or appeal is provided in such case. In conformance with these rules the University president notified Roth before February 1, 1969, that he would not be rehired. Roth received no statement of reasons and no opportunity to challenge the decision. Roth brought this action in the United States District Court for the Western District of Wisconsin. He alleged that the failure to provide reasons and a hearing violated his Fourteenth Amendment right to procedural due process. He also alleged that the non-renewal decision was actually retaliation for statements critical of the University administration that violated his First Amendment rights. The District Court granted summary judgment for Roth on the procedural due process claim. The Court of Appeals for the Seventh Circuit affirmed. The Board of Regents petitioned for a writ of certiorari, which the Supreme Court granted.
View caseAmber Alonzo obtained an ex parte divorce in Nevada after a short stay. Her former husband remained domiciled in New York. Adequate cause existed for New York to enforce a support order against him because the state retained an interest in protecting its long-term domiciliary despite the foreign decree.
Cornelius Vanderbilt, Jr., petitioner, and Patricia Vanderbilt, respondent, were married in 1948. They separated in 1952 while living in California. The wife moved to New York where she has resided since February 1953. In March of that year the husband filed suit for divorce in Nevada. This proceeding culminated, in June 1953, with a decree of final divorce which provided that both husband and wife were “freed and released from the bonds of matrimony and all the duties and obligations thereof. ...” The wife was not served with process in Nevada and did not appear before the divorce court. In April 1954, Mrs. Vanderbilt instituted an action in a New York court praying for separation from petitioner and for alimony. The New York court did not have personal jurisdiction over him. To satisfy any obligations he might owe Mrs. Vanderbilt, it sequestered his property within the State. He appeared specially and, among other defenses to the action, contended that the Full Faith and Credit Clause of the United States Constitution compelled the New York court to treat the Nevada divorce as having ended the marriage and as having destroyed any duty of support which he owed the respondent. While the New York court found the Nevada decree valid and held that it had effectively dissolved the marriage, it nevertheless entered an order, under § 1170-b of the New York Civil Practice Act, directing petitioner to make designated support payments to respondent. The New York Court of Appeals upheld the support order. Petitioner then applied to this Court for certiorari contending that § 1170-b, as applied, is unconstitutional because it contravenes the Full Faith and Credit Clause. The Supreme Court granted certiorari.
View caseNegligence is a legally sufficient cause when the defendant's conduct subjects the plaintiff to the very type of hazard that later produces the injury. The flood or storm does not break the chain if it merely triggers the precise risk the negligence created.
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No. When two forces operate at the same time and each alone would suffice, the defendant's negligence may still be treated as a substantial factor. The presence of another adequate cause does not automatically relieve the negligent actor.
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A traffic violation supplies adequate cause whenever an officer has probable cause to believe it occurred. The stop remains valid even if the officer's subjective goal is to investigate other crimes.
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