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

Cited by