Daniels v. Williams

474 U.S. 327 (1986)

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Nature of the Case

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Facts

Daniels (P), an inmate, slipped and injured himself when a prison guard negligently left a pillow on a staircase. Tort immunity prevented any suit against the institution or guard (D). P filed a Section 1983 action, alleging a violation of due process. The District Court granted D's motion for summary judgment. A panel of the Court of Appeals affirmed, concluding that, even if respondent could make out an immunity defense in state court, petitioner would not be deprived of a meaningful opportunity to present his case. On rehearing, the en banc Court of Appeals affirmed but under reasoning different from that of the panel. The majority ruled that negligent infliction of bodily injury, unlike the negligent loss of property in Parratt, does not constitute a deprivation of any interest protected by the Due Process Clause. The majority believed that the post-deprivation process mandated by Parratt for property losses was not required. The court then unanimously decided that, even if a prisoner is entitled to some remedy for personal injuries attributable to the negligence of state officials, Parratt would bar petitioner's claim if the State provided an adequate post-deprivation remedy. A 6-3 majority also concluded that P had an adequate remedy in state court, even though D asserted that he would rely on sovereign immunity as a defense in a state suit. The majority believed that P's sovereign immunity defense would fail under Virginia law. The Supreme Court granted review.