Newton v. Rumery case brief

Newton v. Rumery case brief summary
480 U.S. 386 (1987)

CASE SYNOPSIS

Petitioners, a town and its officials, sought review by certiorari of an order of the United States Court of Appeals for the First Circuit, which reversed a district court order dismissing petitioner's 42 U.S.C.S. § 1983 action against petitioners. The court of appeals adopted a per se rule invalidating release-dismissal agreements.

CASE FACTS
Respondent was arrested and charged with tampering with a witness. The prosecutor later agreed to dismiss the criminal charges if respondent agreed to release any civil claims he might have against petitioners. After the charges were dismissed, respondent filed suit against petitioners under 42 U.S.C.S. § 1983, alleging that the arrest, defamation, and imprisonment violated his constitutional rights. The district court found that the release was valid and dismissed respondent's suit. The appeals court reversed, adopting a per se rule invalidating release-dismissal agreements. Petitioners sought review by certiorari.

DISCUSSION

• The Court rejected a per se rule because release-dismissal agreements did not pose a more coercive choice than other situations involving waiver of constitutional rights. 
• The Court considered that respondent was a sophisticated businessman, he was not in jail and was represented by an experienced criminal lawyer who drafted the agreement, and he contemplated the agreement for three days before signing it. 
• Thus, because respondent voluntarily waived his right to sue, the agreement was enforceable.

CONCLUSION
The Court reversed the judgment of the court of appeals and remanded the case to the district court for dismissal of respondent's complaint.



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