Constitutional Law - Civil Rights Acts - Civil Liability of State Officials Acting Withing Their Discretionary Powers
Plaintiff was adjudged mentally ill by a county probate judge and ordered committed to a state mental hospital in November 1950. The commitment was made pursuant to a petition made out by the county deputy sheriff on the recommendation of a local attorney. In August of 1952, plaintiff was released from the state mental hospital. He then filed an action in the county circuit court to test the validity of his commitment. The circuit court found that the commitment was void, because of a failure by the authorities to comply with the applicable statutory requirements, and granted a permanent injunction against its enforcement. After a damage action in the state circuit court against the medical superintendent and the director of receiving at the state mental hospital had been dismissed, plaintiff brought a damage action in the federal district court against the probate judge who ordered him committed, the attorney on whose recommendation the petition for commitment was made, and the medical superintendent and director of receiving at the mental hospital. Plaintiff alleged that they had participated at various times in a series of acts which resulted in his confinement, depriving him of his civil rights under color of Michigan law but in violation of the Constitution of the United States. Each defendant filed a motion to dismiss. Held, granted. The Civil Rights Acts were not intended to give relief against persons acting in a private capacity or against errors of judgment on the part of judges of state courts or state executive officials.Kenney v. Hatfield, (D. C. Mich. 1955) 132 F. Supp. 814.