## Facts

- A Nebraska prison inmate ordered hobby materials by mail valued at $23.50.
- After the materials arrived, prison employees failed to follow established mail-receipt procedures, and the packages were lost.
- The inmate alleged the officials negligently caused the loss and sued under 42 U.S.C. § 1983 for deprivation of property without due process under the Fourteenth Amendment.
- Nebraska provided a tort claims procedure allowing compensation for tortious property losses caused by the State, but the inmate did not use it before filing suit.

## Issues

1. Whether a negligent, random, and unauthorized loss of an inmate’s property by state employees constitutes a deprivation of property without due process actionable under 42 U.S.C. § 1983.
2. Whether procedural due process is satisfied when the state provides an adequate post-deprivation remedy for such a loss, making pre-deprivation process impracticable.

## Decision

- The Supreme Court reversed the judgment for the inmate and held he failed to state a claim under § 1983.
- The loss occurred under color of state law, but it was not caused by an established state procedure; it resulted from employees’ unauthorized failure to follow existing procedures.
- Because the loss was random and unauthorized, the State could not practicably provide meaningful pre-deprivation process.
- Nebraska’s tort claims remedy could have fully compensated the inmate and was sufficient process; therefore, there was no procedural due process violation.

## Legal Principles

- A § 1983 plaintiff must show (1) action under color of state law and (2) a deprivation of a federal right; a property loss alone is not enough without a due process violation.
- When a property deprivation is caused by a random and unauthorized act of a state employee, procedural due process does not require pre-deprivation process if the state provides an adequate post-deprivation remedy.
- Due process analysis differs when the deprivation flows from an established state procedure; in that setting, pre-deprivation process is generally feasible and may be required.
- § 1983 is not a general substitute for state tort law; the availability and adequacy of state corrective process matters to whether there is a federal procedural due process claim.

## Conclusion

The Court held that a negligent, unauthorized loss of an inmate’s property by prison employees does not violate procedural due process when the state offers an adequate post-deprivation remedy capable of compensating the loss, so § 1983 relief is unavailable on those facts.


Parratt v. Taylor, 451 U.S. 527 (1981)