Daniels was a prisoner who
hurt himself when he slipped on a pillow that a prison guard left lying on
a staircase.
Daniels sued, claiming that
the guard's negligent act had deprived him of his "liberty interest
in freedom from bodily injury," and was therefore an unconstitutional
violation of procedural due process.
Daniels originally sued as a
regular tort, but was stymied when the prison used the defense of sovereign
immunity.
When he was denied a State
remedy, Daniels argued that he had been deprived of liberty without due
process.
The US Supreme Court found
that government negligence was insufficient to state a claim under the Due
Process Clause.
"Where a government
official's act causing injury to life, liberty, or property is merely
negligent, no procedure for compensation is constitutionally
required."
