Wyatt v. Cole
United States Supreme Court
504 U.S. 158 (1992)
- Written by Whitney Kamerzel , JD
Facts
Bill Cole (defendant) and Howard Wyatt (plaintiff) owned a cattle business together. Cole tried to dissolve the partnership, but Wyatt would not reach an agreement to do so. Mississippi law permitted a citizen to repossess property from another citizen by posting a bond and submitting an affidavit that the citizen was legally entitled to the property. Under this law, Cole, with the help of the sheriff, repossessed cattle and equipment from Wyatt. After a postseizure hearing, the property was returned to Wyatt. Wyatt sued Cole in federal district court under 42 U.S.C. § 1983, arguing that Cole’s seizure of Wyatt’s property under the Mississippi statute was unconstitutional. The district court held that Cole, with the help of the sheriff, violated Wyatt’s constitutional rights, but that Cole was entitled to qualified immunity. The court of appeals affirmed, holding that a private citizen is entitled to qualified immunity from a 42 U.S.C. § 1983 claim if he did not know, nor should he have known, that a statute was unconstitutional. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (O’Connor, J.)
Dissent (Rehnquist, C.J.)
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