Source: cases/42usc1983/us-503-115-collins-v-harker-heights.case
Case source: https://www.neochart.com/catalog/cases/us/volume_503/0115_01/index.html
Neither the text nor the history of the Due Process Clause supports petitioner’s claim that the governmental employer’s duty to provide its employees with a safe working environment is a substantive component of the Due Process Clause.
we have previously rejected claims that the Due Process Clause should be interpreted to impose federal duties that are analogous to those traditionally imposed by state tort law
Petitioner cannot maintain, however, that the city deprived Collins of his liberty when it made, and he voluntarily accepted, an offer of employment.
In sum, we conclude that the Due Process Clause does not impose an independent federal obligation upon municipalities to provide certain minimal levels of safety and security in the workplace and the city’s alleged failure to train or to warn its sanitation department employees was not arbitrary in a constitutional sense.
The city is not vicariously liable under §1983 for the constitutional torts of its agents: It is only liable when it can be fairly said that the city itself is the wrongdoer.
Instead, we concluded that if a city employee violates another’s constitutional rights, the city may be liable if it had a policy or custom of failing to train its employees and that failure to train caused the constitutional violation.
We assume for the purpose of decision that the allegations in the complaint are sufficient to provide a substitute for the doctrine of respondeat superior as a basis for imposing liability on the city for the tor-tious conduct of its agents, but that assumption does not confront the question whether the complaint has alleged a constitutional violation.
More importantly, the statute does not draw any distinction between abusive and nonabusive federal violations.
Our cases do not support the Court of Appeals reading of § 1983 as requiring proof of an abuse of governmental power separate and apart from the proof of a constitutional violation.
Neither the fact that petitioner’s decedent was a government employee nor the characterization of the city’s deliberate indifference to his safety as something other than an “abuse of governmental power” is a sufficient reason for refusing to entertain petitioner’s federal claim under § 1983.
In Monell, the Court held that Congress intended municipalities and other local government entities to be included among those persons to whom § 1983 applies.
casedsl 1 case /us/503/0115-01 name Collins v. City of Harker Heights cite 503 U.S. 115 (1992) court Supreme Court of the United States date 1992-02-26 url catalog/cases/us/volume_503/0115_01/index.html source ir/caselaw/us_503.jsonl sha1=4d955727389c43a8579a747a5747cc9c7bc86b4c chars=26811 law 42usc1983 role applied posture civil; widow's damages suit against city; Rule 12(b)(6) dismissal affirmed by CA5 on "no abuse of governmental power" theory; certiorari; affirmed on the different ground that no constitutional violation was alleged result claimant-lost element deprivation.substantive-due-process : not-satisfied [pleaded] variant affirmative-duty/government-employer-unsafe-workplace fact @527..715 [supports] | On October 21, 1988, Larry Michael Collins, an employee in the sanitation department of the city of Harker Heights, Texas, died of asphyxia after entering a manhole to unstop a sewer line. fact @1049..1304 [supports] | Her complaint alleged that the city violated that right by following a custom and policy of not training its employees about the dangers of working in sewer lines and manholes, not providing safety equipment at jobsites, and not providing safety warnings. fact @13299..13392 [cuts-against absent] | Petitioner does not claim that the city or any of its agents deliberately harmed her husband. fact @13393..13588 [cuts-against absent] | In fact, she does not even allege that his supervisor instructed him to go into the sewer when the supervisor knew or should have known that there was a significant risk that he would be injured. rule @14135..14370 | Neither the text nor the history of the Due Process Clause supports petitioner’s claim that the governmental employer’s duty to provide its employees with a safe working environment is a substantive component of the Due Process Clause. rule @17237..17414 | we have previously rejected claims that the Due Process Clause should be interpreted to impose federal duties that are analogous to those traditionally imposed by state tort law held @16445..16594 | Petitioner cannot maintain, however, that the city deprived Collins of his liberty when it made, and he voluntarily accepted, an offer of employment. held @19841..20164 | In sum, we conclude that the Due Process Clause does not impose an independent federal obligation upon municipalities to provide certain minimal levels of safety and security in the workplace and the city’s alleged failure to train or to warn its sanitation department employees was not arbitrary in a constitutional sense. gloss Two theories both fail: (a) affirmative duty of workplace safety -- no custody, employment was voluntary (DeShaney line); (b) conscience-shocking arbitrariness -- failure to train/warn is an ordinary tort omission and a resource-allocation choice. A state-law (Texas Hazard Communication Act) entitlement, assumed to be a liberty interest, does not change the result. element policy.failure-to-train : satisfied [assumed] variant failure-to-train/deliberate-indifference-to-employee-safety fact @1305..1549 [supports] | The complaint also alleged that a prior incident had given the city notice of the risks of entering the sewer lines and that the city had systematically and intentionally failed to provide the equipment and training required by a Texas statute. rule @8208..8382 | The city is not vicariously liable under §1983 for the constitutional torts of its agents: It is only liable when it can be fairly said that the city itself is the wrongdoer. rule @10489..10725 | Instead, we concluded that if a city employee violates another’s constitutional rights, the city may be liable if it had a policy or custom of failing to train its employees and that failure to train caused the constitutional violation. held @11573..11927 | We assume for the purpose of decision that the allegations in the complaint are sufficient to provide a substitute for the doctrine of respondeat superior as a basis for imposing liability on the city for the tor-tious conduct of its agents, but that assumption does not confront the question whether the complaint has alleged a constitutional violation. gloss Policy element assumed arguendo; the point of the opinion is that Canton "deliberate indifference" goes to municipal responsibility only and does not supply the underlying constitutional violation. element x-abuse-of-governmental-power : not-reached role rule-announced variant rejected-extra-element/abuse-of-power-separate-from-constitutional-violation fact @1815..2080 [cuts-against] | It did not reach the question whether the city had violated Collins’ constitutional rights because it denied recovery on the ground that there had been no “abuse of governmental power,” which the Fifth Circuit had found to be a necessary element of a § 1983 action. rule @2843..2953 | More importantly, the statute does not draw any distinction between abusive and nonabusive federal violations. held @2324..2505 | Our cases do not support the Court of Appeals reading of § 1983 as requiring proof of an abuse of governmental power separate and apart from the proof of a constitutional violation. held @4389..4682 | Neither the fact that petitioner’s decedent was a government employee nor the characterization of the city’s deliberate indifference to his safety as something other than an “abuse of governmental power” is a sufficient reason for refusing to entertain petitioner’s federal claim under § 1983. gloss Not an element at all: the Court rejects the Fifth Circuit's proposed additional element as a matter of law and applies nothing to the facts; the claim then fails on deprivation instead. element person : satisfied [law] variant municipality/city rule @5492..5650 | In Monell, the Court held that Congress intended municipalities and other local government entities to be included among those persons to whom § 1983 applies. gloss Restated, not contested. element color-of-law : not-reached element causation : not-reached element damages : not-reached misfit The core teaching is a RELATION/ORDERING between elements: for a municipal defendant, deprivation (was there a constitutional violation?) and policy (is the city responsible?) are separate inquiries, and satisfying policy (deliberate indifference) cannot bootstrap deprivation. The law file now declares this as constraint municipal-non-bootstrap, but a case file cannot say "this opinion is the source/an application of that constraint"; it records two independent blocks. misfit The court rejects a proposed extra element (abuse of governmental power). v1 records it as not-reached / rule-announced so it is no longer a failed instance, but rule-announced does not carry the DIRECTION of the announcement (requirement rejected vs. adopted); only the rule quote and gloss say "this is not an element". misfit The deprivation block bundles two distinct substantive-due-process theories (affirmative duty vs. shocks-the-conscience) plus a third state-created-liberty-interest theory decided on an arguendo assumption inside a not-satisfied holding; one variant and one basis per block cannot express nested assumptions. misfit Deprivation sub-ids by constitutional right are open-ended (deprivation.substantive-due-process is ad hoc under the "sub by right" convention); the real doctrinal elements live in the Constitution, not in 1983 -- 1983 instances are mostly instances of another "law". misfit OCR damage in the first paragraph reads "42 U. S. C. § 1988" for 1983; a citation-keyed loader would misattribute the statute.