United States v. Lanier
Citation
520 U.S. 259 (1997)
Facts
David Lanier, a Tennessee state judge, sexually assaulted several women in his judicial chambers; he was convicted under 18 U.S.C. § 242 for depriving them of liberty without due process, but the Sixth Circuit reversed on the ground that the constitutional right was not clearly established.
Issue
What standard of fair warning is required for a prosecution under 18 U.S.C. § 242, and must there be a prior decision establishing the constitutional violation on nearly identical facts?
Holding
The Supreme Court reversed the Sixth Circuit, holding that § 242 does not require a prior decision with identical facts; it requires only that the right be clearly established such that an objectively reasonable official would have known the conduct was unlawful.
Rule
Section 242 requires fair warning that the conduct was unconstitutional; the constitutional right need not have been established by a case with identical facts — the violation need only be apparent in light of preexisting law, judged by whether the contours of the right were sufficiently clear that a reasonable official would understand that his conduct violated it.