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 Marshall,
dissenting.
While I join the dissenting opinion of my Brother Stevens, I would add one or two additional words. As I view this case, neither "negligence” nor “mere negligence” is involved. Respondent was arrested and not released. This constituted intentional action and not, under these circumstances, negligence. For despite respondent’s repeated protests of misiden-tification, as well as information possessed by the Potter County sheriff suggesting that the name in the arrest warrant was incorrect, see post, at 151 (Stevens, J., dissenting), petitioner and his deputies made absolutely no effort for eight days to determine whether they were holding an innocent man in violation of his constitutionally protected rights.