Lynch v. Household Finance Corp.

Lynch v. Household Finance Corp.
405 U.S. 538 (1972) |
SCOTUS decided 1972-03-23
Jurisdiction level:

State law that allows creditor summary pre-judicial garnishment of debtor’s savings account violates the Equal Protection and Due Process Clauses of the Fourteenth Amendment.

Result: Win
Importance:

The U.S. Supreme Court finds for the first time that deprivation of not only personal liberties but also property rights can violate the Constitution.


Law type: Civil
Topic(s): Debt collection, Due process, Equal protection, and Property rights
State of origin: CT
Attorneys:

David M. Lesser (New Haven Legal Assistance Association) argued the cause for appellants. With him on the briefs was William H. Clendenen, Jr.


Others involved: New Haven Legal Assistance Association (Connecticut) cites this as one of its Cited as notable cases.
Organization role: Sponsor

Last modified: 2020-04-02 11:27
Case internal grade: A | Case internal status: OK |
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CASE DETAILS

(The syllabus is not part of the opinion, but is a summary prepared by the court reporter as a convenience.)

APPEAL FROM THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF CONNECTICUT

Syllabus

Appellee Household Finance Corp. sued appellant Lynch in state court alleging nonpayment of a promissory note, and, prior to serving her with process, garnished her savings account under Connecticut law authorizing summary pre-judicial garnishment. Appellant challenged the validity of the state statutes under the Equal Protection and Due Process Clauses of the Fourteenth Amendment, and sought declaratory and injunctive relief under 42 U.S.C. § 1983 and its jurisdictional counterpart, 28 U.S.C. § 1343(3). The District Court dismissed the complaint on the grounds (1) that it lacked jurisdiction under § 1343(3), as that section applies only if “personal” rights, as opposed to “property” rights, are impaired, and (2) that relief was barred by 28 U.S.C. § 2283, proscribing injunctions against state court proceedings.

Held:

1. There is no distinction between personal liberties and proprietary rights with respect to jurisdiction under 28 U.S.C. § 1343(3). Pp. 405 U. S. 542-552.

(a) Neither the language nor the legislative history of that section distinguishes between personal and property rights. Pp. 405 U. S. 543-546.

(b) There is no conflict between that section and 28 U.S.C. § 1331, and the legislative history of § 1331 does not provide any basis for narrowing the scope of § 1343(3) jurisdiction. Pp. 405 U. S. 546-550.

(c) It would be virtually impossible to apply a “personal liberties” limitation on § 1343(3), as there is no real dichotomy between personal liberties and property rights. It has long been recognized that rights in property are basic civil rights. Pp. 405 U. S. 550-552.

2. Prejudgment garnishment under the Connecticut statutes is levied and maintained without the participation of the state courts, and thus an injunction against such action is not barred by the provisions of 28 U.S.C. § 2283. Pp. 405 U. S. 552-556.

318 F. Supp. 1111, reversed and remanded.

Page 405 U. S. 539

STEWART, J., delivered the opinion of the Court, in which DOUGLAS, BRENNAN, and MARSHALL, JJ., joined. WHITE, J., filed a dissenting opinion, in which BURGER, C.J., and BLACKMUN, J., joined, post, p. 405 U. S. 556. POWELL and REHNQUIST, JJ., took no part in the consideration or decision of the case.