Parratt v. Taylor
451 U.S. 527 (1981)
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Rule of Law:
A negligent deprivation of property by a state employee does not constitute a violation of the Fourteenth Amendment's Due Process Clause if a meaningful post-deprivation remedy is available under state law.
Facts:
- Taylor, an inmate at a Nebraska prison, ordered hobby materials valued at $23.50 by mail.
- The packages containing the materials were delivered to the prison and signed for by two prison employees.
- At the time of delivery, Taylor was in segregation and was not permitted to possess the materials.
- Prison officials subsequently lost the hobby materials and could not locate them or determine what caused their disappearance.
- Taylor alleged the loss was due to the officials' negligence and their failure to follow established procedures for handling inmate mail.
- At the time of the loss, Nebraska state law provided a tort claims procedure allowing individuals to seek compensation for tortious losses caused by the state.
Procedural Posture:
- Taylor sued Warden Parratt and the prison's Hobby Manager in the United States District Court for the District of Nebraska under 42 U.S.C. § 1983.
- The District Court, a trial court, granted summary judgment in favor of Taylor.
- Parratt, the appellant, appealed the decision to the United States Court of Appeals for the Eighth Circuit.
- The Court of Appeals, an intermediate appellate court, affirmed the District Court's judgment in a per curiam order.
- The U.S. Supreme Court granted certiorari to review the decision of the Court of Appeals.
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Issue:
Does the negligent loss of an inmate's personal property by state employees constitute a deprivation of property without due process of law in violation of the Fourteenth Amendment, when the state provides an adequate post-deprivation tort remedy?
Opinions:
Majority - Justice Rehnquist
No, the negligent loss of an inmate's property does not violate the Due Process Clause when an adequate state post-deprivation remedy is available. The Court reasoned that while the loss constituted a 'deprivation' of 'property' under 'color of state law,' it was not 'without due process of law.' Because the deprivation resulted from a random and unauthorized act by a state employee, rather than from an established state procedure, it was impracticable for the state to provide a meaningful pre-deprivation hearing. The availability of a post-deprivation remedy, such as Nebraska's tort claims procedure, provides all the process that is due in such circumstances by offering a means to be made whole for the loss, thus satisfying the requirements of the Fourteenth Amendment.
Concurring - Justice Stewart
No, the availability of a state reparations remedy means Nebraska has done all that the Fourteenth Amendment requires in this context. Stewart expressed extreme doubt that a merely negligent property loss is even a 'deprivation' in the constitutional sense, as it trivializes the Constitution. However, even assuming it is a deprivation, the existence of the state's post-deprivation remedy satisfies due process.
Concurring - Justice Blackmun
No, under these specific circumstances, the state's post-deprivation remedy is sufficient. Blackmun wrote to emphasize the narrowness of the holding, stating it should only apply to negligent deprivations of property. He argued it should not apply to deprivations of life or liberty, nor should it excuse the need for pre-deprivation process for intentional acts by state officials, for which the state can and should implement preventative procedures.
Concurring - Justice Powell
No, a negligent act by a state official that causes an unintended loss of property does not constitute a 'deprivation' within the meaning of the Fourteenth Amendment. Powell argued the constitutional inquiry should end before considering the adequacy of state remedies. He contended that a 'deprivation' connotes an intentional act, and applying the Due Process Clause to mere negligence would trivialize § 1983 and transform the Fourteenth Amendment into a 'font of tort law.'
Concurring-in-part-and-dissenting-in-part - Justice Marshall
No, in theory, an adequate post-deprivation remedy can satisfy due process, but the remedy was not adequate here. Marshall agreed with the majority's legal framework but dissented from its application to the facts. He argued that because the plaintiff was an inmate with limited access to information, prison officials had an affirmative duty to inform him of the available state tort remedy. Because they failed to do so, the remedy was not truly adequate for him, and his § 1983 claim should have been permitted.
Analysis:
This case established what is known as the Parratt-Hudson doctrine, which significantly limits § 1983 procedural due process claims arising from the loss of property. The decision diverts many potential constitutional tort claims against state actors from federal court back to state court systems. It creates a critical distinction between deprivations caused by established state procedures, which require pre-deprivation process, and those caused by 'random and unauthorized' acts, for which an adequate post-deprivation remedy suffices. This framework forces courts to analyze the nature of the state action before determining what kind of process is constitutionally required.
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