Parratt v. Taylor
Posted on Friday, December 6th, 2013 at 4:45 pmParratt v. Taylor, 451 US 527 (1981). The Supreme Court’s decision in Parratt is not directly referenced in any of the documents filed in Foleys v. Orange County. It is referenced only indirectly through cases the Court cites in its orders 150 and 290: Williamson County Regional Planning Commission v. Hamilton Bank of Johnson City, 473 U.S. 172 (1985); Fetner v. City of Roanoke, 813 F.2d 1183 (11th Cir. 1987); Soldal v. Cook County, Illinois, 506 U.S. 56 (1992); and, McKinney v. Pate, 20 F.3d 1550 (11th Cir. 1994).
Parratt, a prison inmate, claimed he was negligently deprived of property (a hobby kit) by employees of a Nebraska prison who failed to properly follow the prison’s mail handling procedure. The Court decided that because the deprivation was "random and unauthorized", the Court could not require a pre-deprivation hearing, but only a post-deprivation hearing.