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Pierson v. Ray

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Supreme Court of the United States
Pierson v. Ray
Term: 1967
Important Dates
Argument: January 11, 1967
Decided: April 11, 1967
Outcome
Affirmed in part, reversed in part, and remanded
Vote
8-1
Majority
Earl Warren • Hugo Black • Tom Clark • Abe Fortas • John Harlan • William Brennan • Potter Stewart • Byron White
Dissenting
William Douglas


Pierson v. Ray was a case argued before the Supreme Court of the United States on January 11, 1967, during the court's 1966-1967 term. The court affirmed a Fifth Circuit ruling that a local judge had absolute immunity from lawsuits under 42 U.S.C. § 1983 for actions taken within the scope of his judicial role. The court also ruled police officers had qualified immunity.[1]

HIGHLIGHTS
  • The case: A group of white and Black clergymen used a segregated bus terminal in Mississippi as a peaceful protest. They were arrested and convicted for breach of peace under a state law later deemed unconstitutional. They sued the police officers and judge for civil rights violations under § 1983.
  • The issue: Were the police officers and judge liable for damages under § 1983 for an unconstitutional arrest and conviction?
  • The outcome: The Supreme Court affirmed in part and reversed in part the Fifth Circuit's ruling. It held that a judge has absolute immunity and police officers have a defense of good faith and probable cause for actions under § 1983. The case was remanded.


    • Timeline

    The following timeline details key events in this case:

    • April 11, 1967: U.S. Supreme Court affirmed in part and reversed in part the Fifth Circuit's decision and remanded the case.
    • January 11, 1967: Oral arguments were heard.
    • October 25, 1965: The Fifth Circuit reversed and remanded the lower court's ruling and held that the local justice had immunity under both § 1983 and the state common law and that the police officers had qualified immunity under the state common law.[2]

    Background

    In 1961, a group of white and Black clergymen used a segregated bus terminal in Jackson, Mississippi, as part of a peaceful protest to promote racial integration. They were arrested and charged with breaching the peace under a disorderly conduct state law later ruled unconstitutional in 1965. The clergymen waived a jury trial and were found guilty by police justice James Spencer and sentenced to four months in jail and a $200 fine. After appealing the case de novo, the case was dismissed.[1]

    The clergymen filed a lawsuit against the police officers and police justice for damages under 42 U.S.C. § 1983—which states that "every person" who deprives another of his civil rights under the color of law is liable—and at common law for false arrest and imprisonment. The jury found for the police officers and police justice.[1]

    On appeal, the Court of Appeals for the Fifth Circuit held that the police justice had immunity for actions taken within his judicial role under both § 1983 and the state common law. They also held that the police officers had immunity if they had probable cause to believe the disorderly conduct state law was valid; the court said they were not required to predict which laws were constitutional. No immunity was available for the police officers under § 1983 since the disorderly conduct state law was later deemed unconstitutional.[1]

    Text of 42 U.S.C.S. § 1983

    Section 1983 states the following:

    “

    Every person who, under color of any statute, ordinance, regulation, custom, or usage, of any State or Territory or the District of Columbia, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress, except that in any action brought against a judicial officer for an act or omission taken in such officer’s judicial capacity, injunctive relief shall not be granted unless a declaratory decree was violated or declaratory relief was unavailable. For the purposes of this section, any Act of Congress applicable exclusively to the District of Columbia shall be considered to be a statute of the District of Columbia.[3]

    		”
    —42 U.S.C.S. § 1983[4]

    Questions presented

    The petitioner presented the following questions to the court:

    Questions presented:
    • Is a local judge liable for damages under § 1983 for an unconstitutional conviction?
    • Should the police officers be permitted to assert the defense of good faith and probable cause to an action under § 1983 for an unconstitutional arrest?
    • Should the plaintiffs be denied recovery against the police officers if they acted with the anticipation they would be illegally arrested?

    Outcome

    Chief Justice Earl Warren delivered the opinion of the court, in which Justices Black, Brennan, Clark, Fortas, Harlan, Stewart, and White joined. Justice William Douglas dissented. The court affirmed in part and reversed in part the Fifth Circuit's ruling. The case was remanded to the trial court for a new trial.

    Opinion

    In his opinion, Justice Warren wrote on immunity for judges:

    “ We find no difficulty in agreeing with the Court of Appeals that Judge Spencer is immune from liability for damages for his role in these convictions. The record is barren of any proof or specific allegation that Judge Spencer played any role in these arrests and convictions other than to adjudge petitioners guilty when their cases came before his court. Few doctrines were more solidly established at common law than the immunity of judges from liability for damages for acts committed within their judicial jurisdiction, as this Court recognized when it adopted the doctrine, in Bradley v. Fisher, 13 Wall. 335 (1872). This immunity applies even when the judge is accused of acting maliciously and corruptly ...[3] ”


    Warren wrote on immunity for the police officers:

    “ We hold that the defense of good faith and probable cause, which the Court of Appeals found available to the officers in the common-law action for false arrest and imprisonment, is also available to them in the action under 1983.[3] ”


    Warren wrote on the right to recover damages under § 1983:

    “ The case contains no proof or allegation that they in any way tricked or goaded the officers into arresting them. The petitioners had the right to use the waiting room of the Jackson bus terminal, and their deliberate exercise of that right in a peaceful, orderly, and inoffensive manner does not disqualify them from seeking damages under 1983.[3] ”

    Text of the opinion

    The following embedded document contains the text of the opinion.

    Audio

    Listen to the recorded oral argument here.

    Transcript

    Read the oral argument transcript here.

    See also

    External links

    Footnotes

    1. ↑ 1.0 1.1 1.2 1.3 Pierson v. Ray, 386 U.S. 547 (1967)
    2. ↑ Pierson v. Ray, 352 F.2d 213 (5th Cir. 1965)
    3. ↑ 3.0 3.1 3.2 3.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    4. ↑ Legal Information Institute, "42 U.S.C.S. § 1983," accessed July 2, 2020
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