Deprivation of Fourteenth Amendment Substantive Due Process

OR · 42usc1983:deprivation.substantive-due-process

Protects fundamental rights and guards against executive abuse of power that "shocks the conscience" (County of Sacramento v. Lewis), but does not constitutionalize ordinary state tort law or impose an affirmative workplace-safety duty absent custody (DeShaney; Collins).

Exact element source

to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws
Source: docroot/ir/usc/title42.jsonl#title42_sec1983; Unicode character offsets [306:402] (end exclusive); SHA-256 88fe01322b9d94860a669ec452f558146e2745845070bc43583671ce12acb2bb.

Routes and case patterns

Curated routes and observed case patterns
RouteDefinitionMerits instance blocksDistinct merits casesExamples (up to 3 cases per count group)
affirmative-duty
provisional; provisional (1 case)
Whether the State owed an affirmative duty to protect or provide (DeShaney, Collins).1
Satisfied 0; not satisfied 1; excluded context 0
1

Collins v. City of Harker Heights — 503 U.S. 115 (1992) · Supreme Court of the United States · 1992 — not · pleaded (42usc1983: author: Fable · not independently reviewed) · applied/merits · counted
Pattern: government-employer-unsafe-workplace

How courts decided this element

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopePatternExact source quotations
Collins v. City of Harker Heights — 503 U.S. 115 (1992) · Supreme Court of the United States · 1992 — not · pleaded (42usc1983: author: Fable · not independently reviewed)Deprivation of Fourteenth Amendment Substantive Due Processnot
Counted merits instance
applied / merits

basis: pleaded

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.
government-employer-unsafe-workplace
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.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [527:715] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [1049:1304] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Petitioner does not claim that the city or any of its agents deliberately harmed her husband.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [13299:13392] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: fact; polarity: cuts-against; absent flag: 1; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [13393:13588] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: fact; polarity: cuts-against; absent flag: 1; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [14135:14370] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [17237:17414] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Petitioner cannot maintain, however, that the city deprived Collins of his liberty when it made, and he voluntarily accepted, an offer of employment.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [16445:16594] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

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.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [19841:20164] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations

interpretation

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.

Collins v. City of Harker Heights — 503 U.S. 115 (1992) · Supreme Court of the United States · 1992 (42usc1983: author: Fable · not independently reviewed)

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.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [14135:14370] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Protects fundamental rights and guards against executive abuse of power that "shocks the conscience" (County of Sacramento v. Lewis), but does not constitutionalize ordinary state tort law or impose an affirmative workplace-safety duty absent custody (DeShaney; Collins).

interpretation

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

Collins v. City of Harker Heights — 503 U.S. 115 (1992) · Supreme Court of the United States · 1992 (42usc1983: author: Fable · not independently reviewed)

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
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [17237:17414] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Protects fundamental rights and guards against executive abuse of power that "shocks the conscience" (County of Sacramento v. Lewis), but does not constitutionalize ordinary state tort law or impose an affirmative workplace-safety duty absent custody (DeShaney; Collins).