Summary of Paul v. Davis
Citation: 424 U.S. 693
Relevant Facts: Edward C. Davis III was listed on a flyer that was distributed to vendors in the Louisville, Kentucky area. The flyer identified “active shoplifters." Charges were ultimately brought against Davis, but when those charges were dropped, Davis sued Edgar Paul, who was the chief of police at the time. Davis argued that the flyer, which had been distributed by the police, had unjustly deprived him of his constitutional rights to due process and in the process stigmatized him.
Issues: The legal issue presented was whether the distribution of the flyer with Davis’ image on it violated his right to privacy and liberty under the Fourteenth Amendment’s Due Process Clause.
Holding: The Supreme Court found that Davis’s constitutional rights had not been violated.
Reasoning: The majority held that Davis’s rights had not been violated. The Court reasoned in part that Davis had put forth an improper claim in asserting that privacy rights pertains to his case. The Court indicated that privacy concerns as envisioned by the Fourteenth Amendment only pertains to issues concerning “marriage, procreation, contraception, family relationships, and child rearing and education.” In other words, those issues concerning matters to be deliberated by people in their personal lives, and not a matter of public safety or law and order. The publication and dissemination of records, including arrests, warrants, etc. do not fall under privacy, because they are inherently public rather than private issues.
Dissent: Justices Brennan, Marshal and White dissented on the grounds that police officers should not arbitrarily be able to label citizens as criminals, which will likely irreparably ruin their reputations, when there are no means of recourse. The justices asserted that being accused of a crime creates a stigma, and therefore, while a public safety issue may exist, there must be a balance in which the rights of the not yet (formally) accused are protected against a possibly overzealous State. The justices argued that, “If there are no constitutional restraints on such oppressive behavior, the safeguards constitutionally accorded an accused in a criminal trial are rendered a sham."
Conclusion: This case is significant because it provides an example in which the Court found that there are distinctions between interests that are constitutionally protected and those that are not. It is also significant because the Court found that right to privacy and by extension privacy rights as articulated under the Due Process Clause do not pertain to matters of reputation when there is a public safety issue. Bluntly, the police were doing their due diligence to find the perpetrators of theft in the community; Davis did not have a right to privacy on that ground.