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State-of-Mind Requirement for Prisoners Under the Due Process Clause of the Fourteenth Amendment - Daniels v. Cannon

NCJ Number
Creighton Law Review Volume: 20 Issue: 1 Dated: (1986-1987) Pages: 291-316
P K Charlton
Date Published
26 pages
In Daniels v. Williams, the U.S. Supreme Court held that allowing the negligent acts of prison official to fall within the scope of the 14th amendment would trivialize the due process clause; in Davidson v. Cannon, it held that a prisoner's injury resulting from a lack of due care by his caretakers also was outside the scope of due process.
The Court's holdings in these two cases limits a prisoner's due process remedies to those 14th amendment violations caused by reckless or intentional State action. While the Court's ruling might serve well as a general rule for nonprisoners, the nexus between inmates and the State is such that the rule, strictly applied, could limit severely the ability of inmates to find redress for legitimate constitutional rights violations of State authorities. The court in its attempt to prevent trivialization of the due process clause may have instead trivialized the nature of the duty owed to prisoners by the State. 246 footnotes.