Logan v. Zimmerman Brush Co.

Logan v. Zimmerman Brush Co.
Supreme Court of the United States
Argued October 14, 1981 Decided February 24, 1982
Full case name	Logan v. Zimmerman Brush Co.
Docket no.	80-5950
Citations	455 U.S. 422 (more) 102 S.Ct. 1148, 71 L.Ed.2d 265, 1982 U.S.LEXIS 75
Argument	Oral argument
Case history
Prior	Writ of prohibition granted, 82 Ill.2d 99, 411 N.E.2d 277 (Ill., 1980), sub nom Zimmerman Brush Co. v. Fair Employment Practices Commission
Holding
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.
Court membership
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Byron White Thurgood Marshall · Harry Blackmun Lewis F. Powell Jr. · William Rehnquist John P. Stevens · Sandra Day O'Connor
Case opinions
Majority	Blackmun, joined by Burger, Brennan, White, Marshall, Stevens
Concurrence	Blackmun, joined by Brennan, Marshall, O'Connor
Concurrence	Powell (in judgment), joined by Rehnquist
Laws applied
U.S. Const. Amd. XIV

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,^[1] 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.^[2] 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.