Bronwyn Randel v. Rabun County School District
DueProcess Takings JusticiabilityDoctri
Does the existence of a state post-deprivation process preclude a procedural due-process claim
QUESTION PRESENTED The Due Process Clause provides that no person may be deprived of life, liberty or property without due process of law. Due process requires notice, an opportunity to be heard, and an unbiased decisionmaker. A hearing that meets due process standards must ordinarily be held prior to the deprivation. The question presented is: Does the existence of a state post-deprivation process preclude a procedural due process claim (a) only where a pre-deprivation process that satisfied constitutional standards would be impracticable, such as because the deprivation was a random or unauthorized act of an errant state official (the rule in ten circuits and under decisions of the highest courts in eight states), or (b) in any case in which, even though compliance with constitutional standards in a pre-deprivation process was practicable, the state postdeprivation process provides some form of remedy for the constitutional deficiency of the pre-deprivation process (the longstanding rule in the Eleventh Circuit)? ii PARTIES The parties are Bronwyn Randel and Rabun County School District.