Synopsis of Rule of Law. Qualified immunity from due process claims analysis asks two questions: (1) Was there a deprivation of a constitutional right, and if so, (2) Was the right clearly established at the time of the deprivation? As for (1), before the State may deprive someone of a protected liberty interest, it must provide certain procedural protections such as notice and opportunity to be heard. As for (2), to be a clearly established constitutional right, the right’s contours “must be sufficiently clear that a reasonable official would understand that what she is doing violates that right.â€
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We review de novo the denial of a motion for summary judgment based on qualified immunity.
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Issue. Whether depriving an individual of her interest in procreation and contraception violates fourteenth amendment due process rights such that qualified immunity is unavailable.
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Held. Yes. Qualified immunity analysis asks two questions: (1) Was there a deprivation of a constitutional right, and if so, (2) Was the right clearly established at the time of the deprivation? In analyzing these questions, the court found that Margaret possessed a protected liberty interest because a personal decision relating to procreation or contraception is such an interest. Moreover, before the State may deprive someone of a protected liberty interest, it must provide certain procedural protections such as notice and opportunity to be heard which it did not do in this case. Thus, the court held that Ruoff’s conduct in coercing Margaret’s sterilization violated her due process right without appropriate procedures. In addition, the court held that the unconstitionality of Ruoff’s alleged conduct was clearly established at the time it occurred because a “reasonable official would understand that what she was doing violates that right.â€Â Accordingly, the court of appeals affirmed the trial court.
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Discussion. There may be situations where involuntary sterilization may be constitutional if it is a narrowly tailored means to achieve a compelling government interest. The State may not, however, dispense with procedural protections in coercing an individual into sterilization, then after the fact argue that it was justified.