Chappell et al. v. Wallace et al.
462 U.S. 296 (1983)
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Rule of Law:
Enlisted military personnel may not maintain a suit for damages against their superior officers for alleged constitutional violations that arise out of or in the course of military service, due to special factors counseling hesitation such as the unique disciplinary structure of the military and Congress's plenary authority over military justice.
Facts:
- A group of five enlisted men, who were members of a minority race, served in the United States Navy aboard a combat vessel.
- Their superior officers included the ship's commanding officer, four lieutenants, and three noncommissioned officers.
- The enlisted men alleged their superiors engaged in racial discrimination against them.
- Specifically, they claimed the officers failed to assign them desirable duties, threatened them, gave them low performance evaluations, and imposed penalties of unusual severity because of their race.
Procedural Posture:
- A group of enlisted Navy men sued their superior officers in the U.S. District Court for the Southern District of California.
- The District Court dismissed the complaint, finding the claims nonreviewable and the officers immune.
- The enlisted men, as appellants, appealed the dismissal to the U.S. Court of Appeals for the Ninth Circuit.
- The Court of Appeals reversed the District Court's dismissal and remanded the case for further proceedings.
- The superior officers, as petitioners, were granted a writ of certiorari by the U.S. Supreme Court to review the decision of the Court of Appeals.
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Issue:
May enlisted military personnel maintain a suit to recover damages from their superior officers for alleged constitutional violations sustained in the course of military service?
Opinions:
Majority - Chief Justice Burger
No. Enlisted military personnel may not maintain a suit for damages against their superior officers for alleged constitutional violations. While Bivens v. Six Unknown Fed. Narcotics Agents authorized damage suits against federal officials for constitutional violations, it also warned against creating such remedies where 'special factors counselling hesitation' are present. The military context presents two such special factors. First, the unique disciplinary structure of the military, which requires a hierarchical system of obedience and command that is fundamentally different from civilian life, would be undermined by allowing enlisted personnel to sue their superiors. Second, the Constitution grants Congress plenary authority over the military, and Congress has exercised this authority by establishing a comprehensive internal system of justice (including the Uniform Code of Military Justice and Boards for Correction of Military Records) to address grievances. Creating a judicial damages remedy would be inconsistent with the legislative scheme established by Congress.
Analysis:
This decision establishes the doctrine of intramilitary immunity, creating a significant exception to the Bivens remedy for constitutional torts. By prioritizing military discipline and congressional authority, the Court severely limits the ability of service members to seek monetary damages for constitutional violations in civilian courts. The ruling solidifies judicial deference to the political branches on military matters and channels service member grievances exclusively into the internal military justice system, regardless of whether that system provides a remedy equivalent to a civil damages award.
