Lugar v. Edmondson Oil Company, Inc. (1981)
- Docket
- 80-1730
- Decided
- 1981-01-01
Summary
Question: Do "state actions" that occur indirectly "under the color of state law" and violate an individual's Fourteenth Amendment rights validate damage recovery suits filed under 42 U.S.C. Section 1983? Conclusion: Yes. Justice Byron R. White delivered the opinion for a 5-4 court. The Fourteenth Amendment prevents "state actions" from intruding unlawfully upon the rights of citizens. Section 1983 offers relief to those who have their rights unlawfully abridged by actions occurring "under the color of state law." The Court decided that a state was liable for damages caused by unconstitutional conduct when two conditions were met. First, "the deprivation [of a constitutional right] must be caused by the exercise of some right or privilege created by the State." Second, "the party charged with the deprivation must be a person who may fairly be said to be a state actor." This includes both state officials and those whom are significantly aided by them. The Court previously found that the states guaranteed the due process of law when placing holds on disputed pieces of property, and therefore they are responsible for violations of this process. Accordingly, when Edmondson used state mechanisms to unconstitutionally deprive Lugar of his property, the state was responsible for compensating him for damages.