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Flagg Bros., Inc. v. Brooks, 436 U.S. 149, 98 S.Ct. 1729, 56 L.Ed.2d 185, 23 UCC Rep.Serv. 1105

Facts

Respondent Shirley Brooks and her family were evicted from their apartment, and their belongings were stored by Flagg Brothers, Inc. After being informed of storage fees, Brooks received a letter threatening to sell her belongings unless she paid her account. She initiated a class action under 42 U.S.C. § 1983, claiming that the sale would violate her constitutional rights. The District Court dismissed the case for lack of state action, but the Court of Appeals reversed, leading to the Supreme Court's review.

According to her complaint, the allegations of which we must accept as true, respondent Shirley Brooks and her family were evicted from their apartment in Mount Vernon, N.Y., on June 13, 1973. The city marshal arranged for Brooks' possessions to be stored by petitioner Flagg Brothers, Inc., in its warehouse.

Issue

Whether a warehouseman's proposed sale of goods entrusted to him for storage, as permitted by New York Uniform Commercial Code § 7–210, is an action properly attributable to the State of New York.

The question presented by this litigation is whether a warehouseman's proposed sale of goods entrusted to him for storage, as permitted by New York Uniform Commercial Code § 7–210 (McKinney 1964), is an action properly attributable to the State of New York.

Rule

A private party's actions can be considered state action only if they are conducted under color of state law, which requires a sufficient level of state involvement or compulsion.

A claim upon which relief may be granted to respondents against Flagg Brothers under § 1983 must embody at least two elements. Respondents are first bound to show that they have been deprived of a right 'secured by the Constitution and the laws' of the United States.

Analysis

The Supreme Court analyzed whether Flagg Brothers' actions could be attributed to the State of New York. The Court concluded that the mere enactment of § 7–210 did not compel the warehouseman to act, nor did it delegate an exclusive state function to him. The absence of public officials' involvement in the sale further distinguished this case from previous rulings that found state action.

The Supreme Court analyzed whether Flagg Brothers' actions could be attributed to the State of New York. The Court concluded that the mere enactment of § 7–210 did not compel the warehouseman to act, nor did it delegate an exclusive state function to him.

Conclusion

The Supreme Court reversed the Court of Appeals' decision, holding that the warehouseman's proposed sale was not state action and therefore did not violate the respondents' constitutional rights.

The judgment of the Court of Appeals holding otherwise is reversed.

Who won?

Flagg Brothers, Inc. prevailed because the Supreme Court found that their actions did not constitute state action under the Fourteenth Amendment.

Flagg Brothers, Inc. prevailed because the Supreme Court found that their actions did not constitute state action under the Fourteenth Amendment.

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