Minneci v. Pollard case summary
132 S. Ct. 617
PROCEDURAL HISTORY: Respondent prisoner in a privately operated federal prison brought an action in federal court against petitioner prison employees alleging that the employees deprived the prisoner of adequate medical care. Upon the grant of a writ of certiorari, the employees appealed the judgment of the U.S. Court of Appeals for the Ninth Circuit which held that the prisoner could pursue an implied right of action under the Eighth Amendment.
FACTS: The employees contended that creating an implied action under the Eighth Amendment was not warranted in view of existing state law remedies. The prisoner argued that federal law should control based on the vagaries of different states' laws, and that state-law remedies did not provide protection based on federal constitutional rights. The U.S. Supreme Court held that no new federal remedy could be implied since state tort law authorized adequate alternative damages actions, providing both significant deterrence and compensation. The prisoner's claim focused on a kind of conduct that typically fell within the scope of traditional state tort law and, in the case of the private rather than government employees, state tort law provided an alternative, existing process capable of protecting the constitutional interests at stake. Further, it appeared that all states provided actions for a claim such as that of the prisoner, the fact that a state law might prove less generous than an implied federal action did not render the state process inadequate, and state tort law and a potential implied federal remedy were not required to be perfectly congruent.
OUTCOME: The judgment upholding an implied right of action was reversed. 8-1 Decision; 1 Concurrence; 1 Dissent.
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132 S. Ct. 617
PROCEDURAL HISTORY: Respondent prisoner in a privately operated federal prison brought an action in federal court against petitioner prison employees alleging that the employees deprived the prisoner of adequate medical care. Upon the grant of a writ of certiorari, the employees appealed the judgment of the U.S. Court of Appeals for the Ninth Circuit which held that the prisoner could pursue an implied right of action under the Eighth Amendment.
FACTS: The employees contended that creating an implied action under the Eighth Amendment was not warranted in view of existing state law remedies. The prisoner argued that federal law should control based on the vagaries of different states' laws, and that state-law remedies did not provide protection based on federal constitutional rights. The U.S. Supreme Court held that no new federal remedy could be implied since state tort law authorized adequate alternative damages actions, providing both significant deterrence and compensation. The prisoner's claim focused on a kind of conduct that typically fell within the scope of traditional state tort law and, in the case of the private rather than government employees, state tort law provided an alternative, existing process capable of protecting the constitutional interests at stake. Further, it appeared that all states provided actions for a claim such as that of the prisoner, the fact that a state law might prove less generous than an implied federal action did not render the state process inadequate, and state tort law and a potential implied federal remedy were not required to be perfectly congruent.
OUTCOME: The judgment upholding an implied right of action was reversed. 8-1 Decision; 1 Concurrence; 1 Dissent.
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Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
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