Supreme Court of the United States
Zinermon v. Burch
February 27, 1990494 U.S. 113
Summary
The Court held that Burch's complaint adequately stated a procedural due process claim under § 1983. Although postdeprivation remedies may satisfy due process when a deprivation is random and unpredictable, that principle did not control because state officials had delegated authority to admit patients and could have provided safeguards before confining a person unable to give informed consent. The judgment affirming the Court of Appeals' reversal of the dismissal was affirmed.
Holding
- Application of the random-and-unauthorized deprivation doctrine to Burch's alleged confinement. The complaint stated a procedural due process claim under § 1983. The defendants could not avoid liability by characterizing Burch's confinement as a random, unauthorized violation for which postdeprivation remedies were sufficient, because the State had delegated them authority to effect the confinement and a concomitant duty to implement safeguards for persons unable to consent.
Docket 87-1965
Cited authorities
- Rule 12(b)(6) of the Federal Rules of Civil Procedure
- Rule 12(b)(6)
- Rule 12(b)(6)
- Rule 12(b)(6)
- Fla. Stat. § 394.467
- CA11
- CA10
- 42 U.S.C. § 1983
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