Daniels v. Williams
474 U.S. 327 (1986)

  • Daniels was a prisoner who hurt himself when he slipped on a pillow that a prison guard left lying on a staircase.
  • Daniels sued, claiming that the guard’s negligent act had deprived him of his “liberty interest in freedom from bodily injury,” and was therefore an unconstitutional violation of procedural due process.
    • Daniels originally sued as a regular tort, but was stymied when the prison used the defense of sovereign immunity.
    • When he was denied a State remedy, Daniels argued that he had been deprived of liberty without due process.
  • The US Supreme Court found that government negligence was insufficient to state a claim under the Due Process Clause.
    • “Where a government official’s act causing injury to life, liberty, or property is merely negligent, no procedure for compensation is constitutionally required.”