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Keywords

tortdue process
tortplaintiffappealdue process

Related Cases

Collins v. City of Harker Heights, Tex., 503 U.S. 115, 112 S.Ct. 1061, 117 L.Ed.2d 261, 60 USLW 4182, 7 IER Cases 233, 15 O.S.H. Cas. (BNA) 1513

Facts

Larry Collins, an employee in the sanitation department of the City of Harker Heights, Texas, died of asphyxia after entering a manhole to unstop a sewer line. His widow brought a § 1983 action, alleging that Collins had a constitutional right to be free from unreasonable risks of harm and that the city violated this right by failing to train its employees about the dangers of working in sewers and not providing necessary safety equipment. The District Court dismissed the complaint, stating that it did not allege a constitutional violation.

On October 21, 1988, Larry Michael Collins, an employee in the sanitation department of the City of Harker Heights, Texas, died of asphyxia after entering a manhole to unstop a sewer line.

Issue

Whether § 1983 provides a remedy for a municipal employee who is fatally injured in the course of his employment due to the city's failure to train or warn its employees about known hazards in the workplace.

The question presented is whether a plaintiff seeking recovery under § 1983 for injury to a governmental employee must demonstrate, inter alia, that the conduct in issue was an abuse of governmental power.

Rule

A municipality cannot be held liable under § 1983 for the constitutional torts of its agents unless the execution of a government's policy or custom inflicts the injury.

A municipality cannot be held liable under § 1983 for the constitutional torts of its agents unless the execution of a government's policy or custom inflicts the injury.

Analysis

The Court analyzed whether the city's failure to train or warn its employees constituted a constitutional violation. It concluded that the Due Process Clause does not impose an independent federal obligation on municipalities to provide certain minimal levels of safety and security in the workplace. The Court found that the widow's claim was more akin to a typical tort claim under state law rather than a constitutional violation.

The Court concluded that the Due Process Clause does not impose an independent federal obligation on municipalities to provide certain minimal levels of safety and security in the workplace.

Conclusion

The Supreme Court affirmed the lower court's decision, concluding that the city's alleged failure to train or warn its sanitation department employees did not constitute a violation of the Due Process Clause.

The judgment of the Court of Appeals is therefore affirmed.

Who won?

City of Harker Heights prevailed because the Supreme Court found that the city's conduct did not violate the Due Process Clause, and thus, the widow's claim under § 1983 was not actionable.

The city prevailed because the Supreme Court found that the city's conduct did not violate the Due Process Clause.

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