Saturday, December 7, 2013

Flagg Bros., Inc. v. Brooks case brief

Flagg Bros., Inc. v. Brooks case brief summary
436 U.S. 149 (1978)


CASE SYNOPSIS
Defendant warehouseman sought review of a decision of the United States Court of Appeals for the Second Circuit, which found sufficient state involvement with the proposed sale of plaintiff's possessions to invoke the provisions of the Due Process Clause of the Fourteenth Amendment.

CASE FACTS
Plaintiff was evicted from her apartment, and her possessions were stored by defendant in its warehouse. After a series of disputes over the validity of charges claimed by defendant, plaintiff received a letter demanding that her account be brought up to date or her furniture would be sold pursuant to the state commercial code. Plaintiff then filed suit against defendant, seeking an injunction against the threatened sale of her belongings and the declaration that such a sale would violate the Due Process and Equal Protection Clauses of the Fourteenth Amendment. An order dismissing the complaint for failure to state a claim was reversed by the court of appeals.

DISCUSSION
  • The Court reversed, holding that plaintiff failed to allege facts that constituted a deprivation of any right secured by the Constitution and laws of the United States. 
  • The state did not compel the sale of plaintiff's possessions but merely announced the circumstances under which its courts would not interfere with a private sale. 
  • Thus, the allegations of plaintiff's complaint did not establish a violation of her Fourteenth Amendment rights either by defendant or the state.

CONCLUSION
The decision finding sufficient state involvement with the proposed sale of plaintiff's possessions to invoke the provisions of the Due Process Clause of the Fourteenth Amendment was reversed. The threatened sale of plaintiff's possessions, pursuant to state commercial code, did not establish a violation of plaintiff's Fourteenth Amendment rights either by defendant warehouse or the state.


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