Martinez v. California

444 U.S. 277 (1980)

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Martinez v. California

United States Supreme Court
444 U.S. 277 (1980)

  • Written by Whitney Kamerzel , JD

Facts

Richard Thomas was convicted of attempted rape and sent to a state mental hospital as a mentally disordered sex offender not amenable to treatment. Thomas was then sentenced to prison for up to 20 years, without the possibility of parole. However, after five years, the parole board (defendant) released Thomas without completing the requisite formalities of paroling a prisoner. Five months later, Thomas killed a 15-year-old girl. The girl’s survivors (plaintiffs) sued the parole board under 42 U.S.C. § 1983 for releasing Thomas when they knew or should have known that Thomas presented a dangerous threat to society. The survivors argued that this decision deprived the 15-year-old girl of her right to life under the Fourteenth Amendment. The state trial court dismissed the complaint. The California Court of Appeal and the California Supreme Court affirmed. The United States Supreme Court granted certiorari.

Rule of Law

Issue

Holding and Reasoning (Stevens, J.)

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