Logan v. Zimmerman Brush Co.

Supreme Court of United States
455 U.S. 422 (1982)

ELI5:

Rule of Law:

A state violates the Due Process Clause of the Fourteenth Amendment when it terminates a statutorily created cause of action, which is a protected property interest, because a state official failed to comply with a procedural deadline outside of the claimant's control.

Facts:

Zimmerman Brush Company hired Láveme L. Logan as a probationary employee.
On November 9, 1979, one month after he was hired, the company discharged Logan.
The company stated the reason for discharge was Logan's short left leg, which they claimed made it impossible for him to perform his duties as a shipping clerk.
On November 14, 1979, Logan filed a charge with the Illinois Fair Employment Practices Commission (Commission), alleging unlawful termination because of his physical handicap.
Under Illinois law, the Commission was required to convene a fact-finding conference within 120 days of the charge being filed, which was by March 13, 1980.
The Commission, through its own inadvertence, scheduled the conference for March 18, 1980, five days after the statutory deadline had expired.
The Commission notified both Logan and the company of the March 18 conference date in January 1980.
Zimmerman Brush Company completed and returned a pre-conference questionnaire by March 10 without objecting to the scheduled conference date.

Procedural Posture:

Láveme Logan filed a discrimination charge against Zimmerman Brush Company with the Illinois Fair Employment Practices Commission (the state's administrative agency).
At the scheduled conference, Zimmerman Brush Company moved to dismiss the charge because the Commission failed to hold the conference within the statutory 120-day period; the motion was rejected.
Zimmerman Brush Company, the respondent in the agency proceeding, petitioned the Supreme Court of Illinois for an original writ of prohibition to stop the Commission's proceedings.
The Supreme Court of Illinois, the state's highest court, held that the 120-day time limit was jurisdictional and granted the writ, effectively terminating Logan's claim.
Logan, the appellant, appealed the decision of the Illinois Supreme Court to the U.S. Supreme Court.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a state's termination of a claimant's cause of action for employment discrimination, due solely to the state agency's inadvertent failure to convene a hearing within a statutorily mandated timeframe, violate the Due Process Clause of the Fourteenth Amendment?

Opinions:

Majority - Justice Blackmun

Yes. Terminating a claimant's cause of action due to a state agency's failure to meet its own statutory deadline violates the Due Process Clause. A cause of action is a species of property protected by the Fourteenth Amendment, and a state may not deprive an individual of that property interest without providing a meaningful opportunity to be heard on the merits. Logan's right to use the state's adjudicatory procedures is a constitutionally protected entitlement grounded in state law that cannot be removed except for cause. The state cannot create such a property interest and then authorize its deprivation through a procedural rule that operates arbitrarily and is beyond the claimant's control. This situation is distinct from cases like Parratt v. Taylor, because the deprivation here results not from a random, unauthorized act of a state employee, but from the established state procedure itself, which makes a post-deprivation tort remedy constitutionally inadequate.

Concurring - Justice Blackmun

Yes. The Illinois statute, as interpreted, also violates the Equal Protection Clause. The law arbitrarily divides claimants into two classes: those whose claims are processed within 120 days and receive a full hearing, and those whose claims are not and are terminated without consideration of their merits. This classification is not rationally related to any legitimate state interest, such as eliminating discrimination or protecting employers from unfounded charges. Terminating potentially meritorious claims in a random manner serves neither of these goals and is the very essence of arbitrary state action.

Concurring - Justice Powell

Yes. The judgment should be affirmed on narrow Equal Protection grounds, avoiding broad pronouncements on due process. The Illinois Supreme Court's decision created two classes of claimants with identical claims who were treated differently based solely on whether the state Commission itself neglected to act in a timely manner. This classification is not rationally related to any legitimate state purpose, such as the timely disposition of claims. It is unfair and irrational to punish claimants for the Commission's failure to convene a timely hearing.

Analysis:

This decision solidifies the principle that a state-created cause of action is a form of property protected by the Due Process Clause. It establishes that a state cannot use a procedural technicality, especially one caused by the state itself, to extinguish that property right without providing a hearing on the merits. The Court's distinction from Parratt v. Taylor is significant, clarifying that when a deprivation results from an 'established state procedure' rather than a 'random and unauthorized act,' a pre-deprivation hearing is required. This holding limits a state's ability to structure its laws in a way that allows procedural hurdles, outside a claimant's control, to be dispositive of substantive rights.

Gunnerbot

AI-powered case assistant

Loaded: Logan v. Zimmerman Brush Co. (1982)

Try: "What was the holding?" or "Explain the dissent"

Premium Feature