Butz v. Economou
 | |
| Butz v. Economou | |
| Reference: 438 US 478 (1978) | |
| Term: 1977-1978 | |
| Important Dates | |
| Argued: November 7, 1977 Decided: June 29, 1978 | |
| Outcome | |
| United States Court of Appeals for the 2nd Circuit affirmed | |
| Majority | |
| Byron White • Thurgood Marshall • Harry Blackmun • Lewis Powell • William Brennan | |
| Dissenting | |
| Chief Justice Warren Burger • Potter Stewart • William Rehnquist • John Paul Stevens | |
Butz v. Economou is a U.S. Supreme Court case that was decided in 1978 concerning the extent of federal administrative officials' personal immunity when exercising their discretionary authority. The court held that federal administrative officials performing discretionary functions are limited to qualified immunity while federal administrative officials who participate in agency adjudication proceedings are entitled to absolute immunity.[1]
Why it matters: The U.S. Supreme Court reconsidered the precedent of absolute immunity for federal administrative officials. The court held that only those officials who participate in agency adjudication proceedings are entitled to absolute immunity. Other federal administrative officials performing discretionary functions are limited to qualified immunity. Federal administrative officials who violate individuals’ constitutional rights, therefore, have exceeded the limits of their authority and cannot claim absolute immunity.[3]
Background
| Administrative State |
|---|
|
| Five Pillars of the Administrative State |
| • Judicial deference • Nondelegation • Executive control • Procedural rights • Agency dynamics |
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The USDA unsuccessfully attempted to revoke or suspend the registration of Arthur Economou's commodity futures commission company due to the agency's claim that Economou had failed to maintain minimum financial requirements. Economou argued that agency officials had not issued a customary warning letter and had initiated the proceedings against him in retaliation for his criticism of the USDA's regulatory program. He sought damages against USDA Secretary Earl Butz and other agency officials for violating his constitutional rights by initiating unauthorized proceedings against him.[1][2]
The district court dismissed Economou’s action against the agency officials, arguing that federal administrative officials were entitled to absolute immunity for discretionary actions within the scope of their official duties. Economou appealed to the United States Court of Appeals for the 2nd Circuit, which reconsidered the doctrine of absolute immunity for federal administrative officials based on its reading of recent U.S. Supreme Court decisions that had granted only qualified immunity to state-level administrative officials. The appeals court reversed the district court's decision on the grounds that federal administrative officials, like their state counterparts, were only entitled to qualified immunity. Butz appealed the ruling to the U.S. Supreme Court. [1][2][3]
Oral argument
Oral arguments were held on November 7, 1977. The case was decided on June 29, 1978.[1]
Decision
The United States Supreme Court affirmed the lower court's ruling in a 5-4 decision. The majority opinion was written by Justice Byron White and joined by justices Thurgood Marshall, Harry Blackmun, Lewis Powell, and William Brennan. Justice William Rehnquist issued an opinion concurring in part and dissenting in part, which was joined by Chief Justice Warren Burger and justices Potter Stewart and John Paul Stevens.[2]
Opinions
Opinion of the court
- See also: Adjudication
Writing for the majority, Justice Byron White rejected the agency officials' claim to absolute immunity. White observed a conflict in the case between the doctrine of absolute immunity for federal administrative officials and the importance of protecting constitutional rights for individuals. White argued that the USDA officials' violation of Economou's constitutional rights exceeded the scope of their discretionary authority and, therefore, they could not be protected by absolute immunity:[2]
| “ | The extension of absolute immunity from damages liability to all federal executive officials would seriously erode the protection provided by basic constitutional guarantees. The broad authority possessed by these officials enables them to direct their subordinates to undertake a wide range of projects -- including some which may infringe such important personal interests as liberty, property, and free speech. It makes little sense to hold that a Government agent is liable for warrantless and forcible entry into a citizen's house in pursuit of evidence, but that an official of higher rank who actually orders such a burglary is immune simply because of his greater authority. Indeed, the greater power of such officials affords a greater potential for a regime of lawless conduct. Extensive Government operations offer opportunities for unconstitutional action on a massive scale. In situations of abuse, an action for damages against the responsible official can be an important means of vindicating constitutional guarantees.[2][4] | ” |
White further noted that absolute immunity is necessary for Article III judges and federal prosecutors in order to protect the independence of the judiciary and ensure that those officials are able to perform their duties without the threat of harassment. Therefore, White argued that absolute immunity should be extended to federal administrative officials who function in analogous roles during agency adjudication, which "shares enough of the characteristics of the judicial process that those who participate in such adjudication should also be immune from suits for damages."[2]
Dissenting opinion
Justice William Rehnquist issued an opinion concurring in part and dissenting in part, which was joined by Chief Justice Warren Burger and justices Potter Stewart and John Paul Stevens. Rehnquist agreed with the court’s decision upholding absolute immunity for federal officials who participate in agency adjudication, but disagreed with the court’s holding that other federal administrative officials were only entitled to qualified immunity. He argued that the court’s decision was based on a flawed interpretation of precedent and would discourage federal administrative officials from carrying out their duties due to the threat of resulting litigation:[2]
| “ | [T]his sort of immunity analysis badly misses the mark. It amounts to saying that an official has immunity until someone alleges he has acted unconstitutionally. But that is no immunity at all: the ‘immunity’ disappears at the very moment when it is needed. The critical inquiry in determining whether an official is entitled to claim immunity is not whether someone has in fact been injured by his action; that is part of the plaintiff's case in chief. The immunity defense turns on whether the action was one taken ‘when engaged in the discharge of duties imposed upon [the official] by law,’ or, in other words, whether the official was acting within the outer bounds of his authority. Only if the immunity inquiry is approached in this manner does it have any meaning. That such a rule may occasionally result in individual injustices has never been doubted, but at least until today, immunity has been accorded nevertheless.[2][4] | ” |
See also
- Federal administrative adjudicators
- Supreme Court of the United States
- Ballotpedia's administrative state coverage
External links
- Full text of case syllabus and opinions (Justia)
- Supreme Court of the United States
- Search Google News for this topic
Footnotes
- ↑ 1.0 1.1 1.2 1.3 Oyez, "Butz v. Economou," accessed September 10, 2018
- ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 JUSTIA, "Butz v. Economou, 438 U.S. 478 (1978)," accessed September 11, 2018
- ↑ 3.0 3.1 Boston College Law Review, "Qualified Immunity for Executive Officials for Constitutional Violations: Butz v. Economou," 1979
- ↑ 4.0 4.1 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
