Connecticut v. Doehr: The Background
The case of Connecticut v. Doehr was a landmark Supreme Court Case that ran in conjunction with a civil action for battery and assault against the respondent Brian K. Doehr. In the case of Connecticut v. Doehr, the petitioner (John DiGiovanni) submitted an application for attachment in the amount of $75,000 on Mr. Doerh’s home in Meridan, Connecticut. The Respondent challenged the constitutionality of the attachment, under the Due Process Clause of the Fourteenth Amendment and the General State Laws of the state of Connecticut.
The case of Connecticut v. Doehr was eventually tried in the United States Supreme Court. The Supreme Court of the United States in Connecticut v. Doehr granted certiorari to resolve the conflict in authority between the Court of Appeals for the Second Circuit’s ruling that the state laws were unconstitutional and the District Court’s decision to affirm the statute.
The synopsis associated with the rule of law of Connecticut v. Doehr states that prejudgment attachments without prior notice and opportunities for hearing violates the Due Process Clause of the Fourteenth Amendment to the United States Constitution.
Connecticut v. Doehr: Facts of the Case
The case of Connecticut v. Doehr starts when the petitioner submitted an application to the Superior Court of the state of Connecticut for an attachment in the amount of $75,000 on the Respondent’s home in Connecticut in connection with a civil action for battery and assault. This particular suit; however, did not involve the Respondent’s land nor did the Petitioner show any interest in the Respondent’s property or home.
The state’s prejudgment attachment laws authorize the attachment of real estate without offering prior notice or the opportunity for a prior hearing. This state law did not require the posting of bonds.
Based on the Petitioner’s affidavit that the Respondent maliciously and willfully assaulted the Petitioner, the state’s Superior Court judge found probable cause to sustain the validity of the claim. This ruling ordered attachment of the Respondent’s home in the amount of $75,000. In response, the Respondent filed suit against the Petitioner in the Federal District Court claiming that the local law was unconstitutional under the Fourteenth’s Amendment’s Due Process Clause.
On appeal, the Court of Appeals reversed the decision and later the Supreme Court of the United States in Connecticut v. Doehr granted certiorari.
The issue in Connecticut v. Doehr revolved on whether a state law that authorized prejudgment attachments of real estate without prior notice for a hearing satisfies the Due Process Clause of the 14th Amendment to the U.S. Constitution.
Connecticut v. Doehr: The Ruling
The ruling in Connecticut v. Doehr stated that no, the prejudgment attachments do not satisfy the Due Process Clause of the Constitution. The factors used to determine what process is due when the government seeks to deprive a person of their property was set forth in the previously rendered Matthews v. Eldridge. The factors to determine such are as follows: consideration of private interest that will be affected by the measure; examination of the risk of erroneous deprivation of interests through the procedures applied; the probable value of alternative or additional safeguards and the government’s interest, including the fiscal and administrative burdens that the substitute or additional procedural requirements would entail.