finding that violations of state laws or policies are not relevant to § 1983 analysis unless they involve “violations of ‘rights, privileges, or immunities secured by the [U.S.] Constitution and [federal] laws’ that occur under color of state law. The statue is thus limited to deprivations of federal statutory and constitutional rights. It does not cover official conduct that allegedly violates state law.”
How later courts described this case
- finding that violations of state laws or policies are not relevant to § 1983 analysis unless they involve “violations of ‘rights, privileges, or immunities secured by the [U.S.] Constitution and [federal] laws’ that occur under color of state law. The statue is thus limited to deprivations of federal statutory and constitutional rights. It does not cover official conduct that allegedly violates state law.”
- holding that the tort *1189 of false imprisonment does not become a violation of the Due Process Clause of the Fourteenth Amendment simply because the defendant is a state official and that “Section 1983 imposes liability for violations of rights protected by the Constitution, not for violations of duties of care arising out of tort law.”
- stating that "[t]he Fourteenth Amendment does not protect against all deprivations of liberty" and noting that the distribution of duties in the criminal justice system does not require a sheriff holding a suspect in custody to "perform an error-free investigation," because ultimate determinations of innocence are left to judge and jury
- holding that the tort of false imprisonment does not become a violation of the Due Process Clause of the Fourteenth Amendment simply because the defendant is a state official and that "Section 1983 imposes liability for violations of rights protected by the Constitution, not for violations of duties of care arising out of tort law."
Written by the judges who cited it.
Distinguished
Distinguished by Yang v. City of Brooklyn Park, 194 F. Supp. 3d 865 (2016)
Baker is also distinguishable.
Distinguished by Robert Fettes v. Adam Hendershot, 375 F. App'x 528 (2010)
The Baker Court specifically instructed that tort analyses were inapplicable to these types of claims because, while a mistaken identity arrest may rise to the level of a tort claim, it is simply not enough for a constitutional violation.
Distinguished by Harris v. Forrest County MS, 254 F. App'x 410 (2007)
We distinguished Baker by reasoning that Baker dealt with the failure to take affirmative steps to investigate the suspect’s innocence, rather than the failure to act on known information.
Distinguished by Alexander Patton v. Raymond Przybylski, 822 F.2d 697 (1987)
In this case, however, the policeman executed the warrant against the wrong person, so Baker is distinguishable.
The opinion
Mr. Justice Blackmun,
concurring.
The Court long has struggled to define the “liberty” protected by the Due Process Clause of the Fourteenth Amendment. The Court today looks to the provisions of the Bill of Rights that have been “incorporated” into the Due Process Clause, including the right to be free from unreasonable seizures, the right to bail, and the right to a speedy trial, and, finding that none of those specifically incorporated rights apply here, concludes that petitioner did not deny respondent due process in holding him in jail during a holiday weekend. Ante, at 144 — 145.
The Court’s cases upon occasion have defined “liberty” without specific guidance from the Bill of Rights. For example, it has found police conduct that “shocks the conscience” to be a denial of due process. Rochin v. California, 342 U. S. 165, 172 (1952). Mr. Justice Harlan once wrote: “This 'liberty’ is not a series of isolated points pricked out in terms of [the Bill of Rights]. It is a rational continuum which, broadly speaking, includes a freedom from all substantial arbitrary impositions and purposeless restraints.” Poe v. Ullman, 367 U. S. 497, 543 (1961) (dissenting opinion). See also Roe v. Wade, 410 U. S. 113, 152-156 (1973).
The Court today does not consider whether petitioner’s conduct “shocks the conscience” or is so otherwise offensive to the “concept of ordered liberty,” Palko v. Connecticut, 302 U. S. 319, 325 (1937), as to warrant a finding that petitioner denied respondent due process of law. Nothing in petitioner’s conduct suggests outrageousness. He had been sheriff for only 40 days when this incident occurred, and, viewing the facts in the light most favorable to respondent, petitioner’s error lay solely in failing to supervise the conduct of the *148 deputies who transferred respondent to the Potter County jail and kept him there over the weekend. The Court of Appeals’ finding that petitioner “intended to confine” respondent rested solely on petitioner’s knowledge of the office procedures, not on any knowledge of respondent or even on an awareness at the time this incident occurred that the procedures might be ineffective. In contrast to the deputies who, as Me. Justice Stevens and Me. Justice Marshall point out, post, at 151-152 and 149, turned a deaf ear to respondent’s protests, petitioner checked the files and released respondent as soon as petitioner became aware of respondent’s claim. The deputies are not parties to this lawsuit. While I concluded in Rizzo v. Goode, 423 U. S. 362, 384-387 (1976) (dissenting opinion), that the reckless failure of a police official to stop a pattern of clearly unconstitutional conduct by his subordinates could be enjoined under § 1983, here there is no indication that petitioner was aware, or should have been aware, either of the likelihood of misidentification or of his subordinates’ action in this case.
I do not understand the Court’s opinion to speak to the possibility that Rochin might be applied to this type of case or otherwise to foreclose the possibility that a prisoner in respondent’s predicament might prove a due process violation by a sheriff who deliberately and repeatedly refused to check the identity of a complaining prisoner against readily available mug shots and fingerprints. Such conduct would be far more “shocking” than anything this petitioner has done. The Court notes that intent is relevant to the existence of a constitutional violation, ante, at 140 n. 1, it reserves judgment as to whether a more lengthy incarceration might deny due process, ante, at 144, and it concludes only that “every” claim of innocence need not be investigated independently, ante, at 145-146. I therefore do not agree with MR. Justice Stevens’ suggestion, post, at 154 n. 14, that a prisoner in respondent’s predicament would be foreclosed from seeking a writ of habeas *149 corpus. Because this is my understanding, and because I agree that the rights surveyed by the Court do not here provide a basis for the damages award respondent seeks, I concur in the judgment of the Court and join its opinion.