Stump v. Sparkman
United States Supreme Court
435 U.S. 349 (1978)
Ora Spitler McFarlin filed a petition in state court to have her mentally challenged 15-year-old daughter, Linda Spitler (plaintiff), undergo a sterilization procedure via tubal ligation, claiming that Linda had stayed out overnight with older boys and younger men on several occasions. The petition was approved ex parte by Judge Harold Stump (defendant), without a hearing, on the same day the petition was submitted. Judge Stump’s approval was not placed on the trial docket or filed with the court clerk’s office. Linda underwent the operation under the belief that she was having her appendix removed. Two years later, Linda married Leo Sparkman (plaintiff), and Linda’s inability to become pregnant led her to discover that the sterilization procedure had been performed. Linda and her husband filed suit in federal district court against Ora, Judge Stump, the attorney who drafted the petition, the physicians who had performed the procedure, and the hospital where the procedure had taken place. The plaintiffs sought damages and raised pendent state claims for assault and battery, medical malpractice, and loss of potential fatherhood. The district court concluded that each of the plaintiffs’ constitutional claims required a showing of state action and that Judge Stump was the only state actor. Further, Judge Stump was completely immune from damages liability under the doctrine of judicial immunity. The plaintiffs appealed. The court of appeals reversed and held that Judge Stump had not acted within his jurisdiction and was thus not immune from damages liability. The United States Supreme Court granted certiorari to review.
Rule of Law
Holding and Reasoning (White, J.)
What to do next…
Unlock this case brief with a free (no-commitment) trial membership of Quimbee.
You’ll be in good company: Quimbee is one of the most widely used and trusted sites for law students, serving more than 724,000 law students since 2011. Some law schools—such as Yale, Berkeley, and Northwestern—even subscribe directly to Quimbee for all their law students.Unlock this case briefRead our student testimonials
Learn more about Quimbee’s unique (and proven) approach to achieving great grades at law school.
Quimbee is a company hell-bent on one thing: helping you get an “A” in every course you take in law school, so you can graduate at the top of your class and get a high-paying law job. We’re not just a study aid for law students; we’re the study aid for law students.Learn about our approachRead more about Quimbee
Here's why 724,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 45,500 briefs, keyed to 983 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.