Paul v. Davis
Encyclopedia
Paul v. Davis, 424 U.S. 693
(1976), is a United States Supreme Court case in which a sharply divided Court held that the plaintiff, whom the local police chief had named an "active shoplifter," suffered no deprivation of liberty resulting from injury to his reputation. The plaintiff sued the local police under a federal civil rights law after the shoplifting charges were dismissed. Justice Rehnquist found that reputation alone was not a constitutionally protected interest.
The case arose after the Louisville police chief circulated a flier on which respondent's mug shot was displayed. The photograph was taken upon respondent's prior arrest, and the flier was intended to help local retailers identify shoplifters. The Court held that petitioner's alleged defamation, a typical state tort claim, was not actionable under the Due Process Clause and 42 U.S.C. § 1983. The procedural guarantees of the Due Process Clause could not be the source for a body of general federal tort law. The Court also found that respondent's injury to reputation was not specially protected by § 1983 and the Due Process Clause. Damage to reputation, alone, apart from some more tangible interests, was not sufficient to invoke the protection of the Due Process Clause. Further, the police chief did not deprive respondent of any state-provided right, and respondent's case was not within the constitutional zone of privacy. The Court reversed the judgment.
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(1976), is a United States Supreme Court case in which a sharply divided Court held that the plaintiff, whom the local police chief had named an "active shoplifter," suffered no deprivation of liberty resulting from injury to his reputation. The plaintiff sued the local police under a federal civil rights law after the shoplifting charges were dismissed. Justice Rehnquist found that reputation alone was not a constitutionally protected interest.
The case arose after the Louisville police chief circulated a flier on which respondent's mug shot was displayed. The photograph was taken upon respondent's prior arrest, and the flier was intended to help local retailers identify shoplifters. The Court held that petitioner's alleged defamation, a typical state tort claim, was not actionable under the Due Process Clause and 42 U.S.C. § 1983. The procedural guarantees of the Due Process Clause could not be the source for a body of general federal tort law. The Court also found that respondent's injury to reputation was not specially protected by § 1983 and the Due Process Clause. Damage to reputation, alone, apart from some more tangible interests, was not sufficient to invoke the protection of the Due Process Clause. Further, the police chief did not deprive respondent of any state-provided right, and respondent's case was not within the constitutional zone of privacy. The Court reversed the judgment.