About: Logan v. Zimmerman Brush Co.

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Logan v. Zimmerman Brush Co., 455 U.S. 422, is a unanimous 1982 decision of the U.S. Supreme Court concerning the Due Process Clause of the Fourteenth Amendment. The Court held that the petitioner was entitled to have his discrimination complaint adjudged by Illinois's Fair Employment Practices Commission (FEPC), which had dismissed it for its own failure to meet a deadline. The decision reversed the Illinois Supreme Court's holding to the contrary two years prior.

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  • Logan v. Zimmerman Brush Co., 455 U.S. 422, is a unanimous 1982 decision of the U.S. Supreme Court concerning the Due Process Clause of the Fourteenth Amendment. The Court held that the petitioner was entitled to have his discrimination complaint adjudged by Illinois's Fair Employment Practices Commission (FEPC), which had dismissed it for its own failure to meet a deadline. The decision reversed the Illinois Supreme Court's holding to the contrary two years prior. Logan, one of whose legs was shorter than the other, had been hired by Zimmerman in 1979 as a machine operator; when that proved beyond his capabilities, he was made a shipping clerk. A month later the company fired him for poor performance; within a week Logan brought a claim with FEPC, alleging he had been discriminated against due to his disability. FEPC was required to hold a factfinding conference with both parties within four months; it accidentally scheduled the one in Logan's case a week after that period ended. The company moved to dismiss the claim on those grounds; after FEPC's denial it petitioned the state Supreme Court for a writ of prohibition which was granted on the grounds that the statutory time limit was mandatory. The U.S. Supreme Court granted Logan certiorari to argue on appeal that his constitutional rights to equal protection and due process of law had been violated. Justice Harry Blackmun, writing for the Court, followed some of its other recent cases in holding that when the state created a process for Logan to seek redress, it had also created a property interest in any claims filed through that process which could not itself be deprived without due process. Unusually, Blackmun also wrote a separate concurrence to the majority opinion, joined by three other justices, arguing that the Illinois Supreme Court had also violated Logan's right to equal protection of the laws by arbitrarily creating two classes of complainants but only granting full rights to one purely on the basis of its own deadline. Justice Lewis Powell also concurred, but would have decided the case on narrower grounds specific to Logan's circumstances, rejecting Blackmun's "broad pronouncements". The Court has not revisited Logan in any later case, but it has often been cited as establishing a test for when due process has been denied. Lower courts have sometimes had to choose between Logan and the Parratt v. Taylor decision two years earlier (later overruled in part) as guiding precedent based on the record before them. Legal scholars have, in considering how it held Logan's claim a property interest, found it to straddle the line between procedural and substantive due process. It has also been described as the first time a majority of justices agreed that a challenged regulation failed the rational basis test under the Fourteenth Amendment. In the wake of the decision Illinois reformed the statute and replaced the FEPC with the Illinois Human Rights Commission, part of the newly created Illinois Department of Human Rights. (en)
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  • Logan v. Zimmerman Brush Co. (en)
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  • 17280.0
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  • Powell (en)
  • Blackmun (en)
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  • 1983-07-06 (xsd:date)
  • 1988-05-09 (xsd:date)
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  • Hunter (en)
  • Rodowsky (en)
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  • Karen M. (en)
dbp:fullName
  • Board of County Commissioners of Calvert County v. Denzil Pritchard et ux (en)
  • Charles C. Holman Jr. v. Gary J. Hilton, Superintendent, New Jersey State Prison, Trenton, Robert Hatrak, Superintendent, New Jersey State Prison, Rahway, Donald Tucker, Assistant to the Superintendent, New Jersey State Prison, Trenton, Joseph Call, Chairman of Institutional Classification Committee, Captain A. Richardson, Captain at New Jersey State Prison, Trenton, Captain R. Curran, Captain at New Jersey State Prison, Rahway, and Lieutenant Williams, Lt., at New Jersey State Prison, Trenton (en)
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  • State administrative dispute resolution agency dismissal of employee's discrimination claim because of its own failure to follow deadlines is denial of due process where employee had complied with procedural rules; claim of employment discrimination is a protected property interest under Due Process Clause. Illinois Supreme Court reversed. (en)
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  • Due process (en)
  • due process (en)
  • equal protection (en)
  • zoning (en)
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  • Logan v. Zimmerman Brush Co. (en)
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  • Blackmun (en)
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  • Holman v. Hilton (en)
  • Board of County Commissioners of Calvert County v. Pritchard (en)
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  • State law that barred suits by inmates against state or its agencies or officials in state court while they were incarcerated violates their rights to equal protection and due process. District of New Jersey affirmed. (en)
  • Denial of site plan approval as incompatible with new zoning was constitutional even where plan was filed on eve of grace period deadline since respondents had previous two years to act and could have been granted extensions of time limits had they done so, thus state action was not arbitrary and out of respondents' control. Court of Special Appeals reversed (en)
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  • dismissed at trial in favor of petitioners, reversed on appeal (en)
dbp:title
  • Applying the Parratt/Hudson Doctrine: Defining the Scope of the Logan Established State Procedure Exception and Determining the Adequacy of State Postdeprivation Remedies (en)
dbp:url
  • https://repository.uchastings.edu/cgi/viewcontent.cgi?article=1347&context=hastings_constitutional_law_quaterly|volume=13|journal=Hastings Const. L.Q. (en)
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  • Logan v. Zimmerman Brush Co., 455 U.S. 422, is a unanimous 1982 decision of the U.S. Supreme Court concerning the Due Process Clause of the Fourteenth Amendment. The Court held that the petitioner was entitled to have his discrimination complaint adjudged by Illinois's Fair Employment Practices Commission (FEPC), which had dismissed it for its own failure to meet a deadline. The decision reversed the Illinois Supreme Court's holding to the contrary two years prior. (en)
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  • Logan v. Zimmerman Brush Co. (en)
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