Lugar v. Edmondson Oil Co.
457 U.S. 922 (1982)

  • Lugar owned a gas station in Virginia, but owed Edmondson money.
  • Edmondson sued to collect the debt.
    • Edmonson also got a prejudgement attachment against Lugar’s property so Lugar couldn’t sell or destroy it while the case was pending.
    • Lugar did not appear in court and did not have the ability to argue against the attachment.
  • Lugar sued, claiming that he had been deprived or property without due process.
    • Virginia argued that they weren’t depriving anybody of anything. Virginia didn’t want Lugar’s gas station, they were only acting on Edmondson’s behalf.
      • Basically, they argued that this was a private action, and therefore not constitutionally protected by the State Action Doctrine, which says that only governmental actions are bound by the Constitution.
    • Lugar argued that Virginia was a participant in the taking, and therefore he should be protected by constitutional guarantees.
  • The US Supreme Court found for Lugar.
    • The US Supreme Court found that when a State creates a system whereby State officials will attach property on the ex parte application of one party in a private dispute (aka a prejudgement attachment), the State has become ‘entangled’ in the dispute, and therefore constitutional guarantees apply.
      • That’s the Entanglement Exception to the State Action Doctrine.
  • There are two questions to ask in deciding whether the Entanglement Exception applies:
    • Does the claimed constitutional deprivation result from the exercise of a right or privilege having its source in State authority?
    • Can the private party charged with the deprivation be described in all fairness as a State actor?