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Crawford-El v. Britton

523 U.S. 574 (1998)

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Crawford-El v. Britton

United States Supreme Court

523 U.S. 574 (1998)

Facts

Leonard Crawford-El (plaintiff) was serving a life sentence in a prison where Patricia Britton (defendant) was a corrections officer. Crawford-El was transferred to a new prison due to overcrowding. Britton shipped Crawford-El’s personal items, including legal paperwork, to Crawford-El’s family instead of the new prison, which cost Crawford-El the price of the shipment and the loss of the items for several months. Crawford-El sued Britton under 42 U.S.C. § 1983, alleging Britton purposely withheld the legal materials because Britton wanted to restrict Crawford-El’s constitutional right to access the courts. The district court dismissed Crawford-El’s case for failing to meet heightened pleading requirements, and Crawford-El appealed. The court of appeals affirmed but allowed Crawford-El to refile the case. The district court dismissed Crawford-El’s second complaint for the same reason. On appeal, the court of appeals held that Crawford-El did not have to meet heightened pleading requirements, but that Crawford-El needed to prove Britton’s improper motive by clear and convincing evidence in order to succeed at trial. The Supreme Court granted certiorari to determine whether the court of appeals’ holding was accurate.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

Concurrence (Kennedy, J.)

Dissent (Scalia, J.)

Dissent (Rehnquist, C.J.)

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