Stafford v. Briggs (1978)
- Docket
- 77-1546
- Decided
- 1978-01-01
Summary
Question: Do the venue provisions in Section 2 of the Mandamus and Venue Act of 1962 apply to officers of the federal government acting in their individual capacities? Conclusion: No. Chief Justice Warren E. Burger delivered the opinion of the 5-2 majority. The Supreme Court held that the language of the statute clearly indicated that Congress meant to restrict the applicability of the statute to employees currently employed by the government at the time of filing. Additionally, the legislative history of the statute shows Congress’ desire to restrict civil actions against governmental officials to those acting in their official capacity. Congress only allowed governmental officials to be sued nominally in their individual capacity in order to circumvent some vestiges of sovereign immunity. The Court held that, regardless of the venue, the case must be essentially against the United States government, rather than against officers in their individual capacities. Justice Potter Stewart wrote a dissent and argued that the Act unambiguously allowed civil suits to be brought against government employees in their individual capacities to circumvent the doctrine of sovereign immunity. He argued that the legislative history supported a broader reading of what the Act allows in civil suits against government officers. Justice William J. Brennan, Jr. joined in the dissent. Justice Byron R. White did not participate in the discussion or decision of this case. Justice Thurgood Marshall did not participate in the decision of this case.