In the 1985 case Daniels v. Williams, the United States Supreme Court ruled that negligence claims do not constitute a violation of due process under the Fourteenth Amendment. The case was brought by an inmate who slipped on a pillow left on a staircase by Deputy Sheriff David Lee Williams at Hampton Roads Regional Jail in Virginia. The plaintiff, Darnell Daniels, argued that his injury resulted from negligent action and thus constituted "punishment" without due process of law. However, Justice Byron White wrote for the majority opinion stating that while many wrongs are done intentionally or negligently which may be actionable under state tort law, they do not automatically become constitutional violations merely because the victim is a prisoner. Therefore, to claim deprivation of rights protected by Due Process Clause requires more than mere negligence; it requires deliberate indifference or intentional acts.

In the dissenting opinion for Daniels v. Williams, Justice Stevens argued that the majority's decision to dismiss Daniels' claim on the basis of a lack of "intent" was too narrow an interpretation of the Due Process Clause. He contended that negligence could indeed be considered a deprivation under this clause, especially in cases where state officials have custody and control over individuals (like prisoners). In his view, when such officials act negligently leading to harm or injury, it should be seen as a violation of constitutional rights because these individuals are unable to protect themselves due to their circumstances. Therefore, he believed that Daniels should have been allowed to proceed with his lawsuit against Deputy Sheriff Williams for leaving a pillow on prison stairs which caused him injury.