Wednesday, November 6, 2013

Lugar v. Edmondson Oil Co. case brief

Lugar v. Edmondson Oil Co. case brief summary
457 U.S. 922 (1982)

CASE SYNOPSIS
Petitioner debtor appealed from the order of the United States Court of Appeals for the Fourth Circuit that held that petitioner failed to state a claim for relief under 42 U.S.C.S. § 1983 on the basis that petitioner did not allege that respondent creditor acted under color of state law when respondent sought and received execution of a writ of attachment on petitioner's property that was later declared invalid for procedural defect.

CASE FACTS
Respondent creditor filed an action in state court and sought prejudgment attachment of petitioner debtor's property. The county sheriff executed a writ of attachment that effectively sequestered petitioner's property. The attachment was later dismissed on the basis that respondent did not establish the statutory grounds for attachment.


PROCEDURAL HISTORY
Petitioner filed a 42 U.S.C.S. § 1983 action against respondent, alleging that it acted jointly with the state to deprive him of his property without due process of law. The district court held that no claim for relief under § 1983 was stated because respondent was not a state actor. The court of appeals affirmed on the ground that there was no allegation of conduct under color of state law.

DISCUSSION

  • The court granted certiorari and reversed and remanded, holding that petitioner presented a valid claim under § 1983 that challenged the constitutionality of the state attachment statute because respondent acted jointly with the state in securing petitioner's property. 
  • The court held that because petitioner was deprived of his property through state action, respondent therefore acted under color of state law in participation of that deprivation.

CONCLUSION
The court granted certiorari and reversed and remanded the order of the court of appeals which held that petitioner debtor did not state a claim for relief in a civil rights action against respondent creditor because respondent acted under color of state law in joint participation with the state to deprive petitioner of his property through the execution of a state writ of attachment.

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