## Facts

- Daniels, a state prisoner in the Richmond, Virginia City Jail, slipped on a pillow left on a stairway and suffered back and ankle injuries.
- He alleged the pillow was negligently left on the stairs by Williams, a deputy sheriff/correctional officer.
- Daniels sued under 42 U.S.C. § 1983, claiming the negligence deprived him of a Fourteenth Amendment liberty interest in bodily integrity without due process.
- He argued Virginia sovereign immunity barred an adequate state tort remedy, making federal relief appropriate.

## Issues

1. Whether a state official’s negligent act causing unintended injury constitutes a “deprivation” of life, liberty, or property under the Fourteenth Amendment Due Process Clause.
2. Whether such negligence can support damages liability under 42 U.S.C. § 1983 on a due process theory.

## Decision

- The Supreme Court affirmed the Fourth Circuit’s judgment for Williams.
- The Court held the Due Process Clause is not implicated by a state official’s negligent act causing unintended loss of or injury to life, liberty, or property.
- The Court overruled *Parratt v. Taylor* to the extent it suggested negligence could itself amount to a constitutional “deprivation.”

## Legal Principles

- Due process protects against arbitrary exercises of governmental power; mere lack of due care is a tort concept and does not amount to a constitutional deprivation.
- A § 1983 due process claim requires more than negligence; absent a constitutional deprivation, the availability or adequacy of state post-deprivation remedies is not reached.
- The Constitution does not displace ordinary state tort law governing accidental injuries, including in custodial settings.
- A jailer’s “special duty of care” under state tort law is not, by itself, a federally protected liberty interest enforceable as a due process right.

## Conclusion

The Court held that negligent conduct by a state official that unintentionally causes physical injury does not trigger the Fourteenth Amendment’s Due Process Clause and therefore cannot support a § 1983 claim for damages based solely on negligence.


Daniels v. Williams, 474 U.S. 327 (1986)