In the 1980 case Parratt et al. v. Taylor, the U.S Supreme Court ruled that a negligent act by a state official does not constitute a violation of due process under the Fourteenth Amendment if an adequate post-deprivation remedy is available to redress any harm suffered. The case arose when Robert Taylor, an inmate in Nebraska's penal system, ordered hobby materials worth $23.50 but never received them despite their delivery at his prison facility; he alleged that this constituted deprivation of property without due process of law and sought damages from prison officials under Section 1983 (a federal statute allowing lawsuits for civil rights violations). The court held that since Nebraska had an adequate tort claims procedure through which Taylor could seek compensation for his loss, there was no constitutional violation.

In the dissenting opinion for Parratt v. Taylor, Justice Blackmun argued that the majority's ruling effectively eliminated a prisoner's ability to seek redress under Section 1983 for property deprivations caused by state employees' random and unauthorized acts. He contended that this was inconsistent with previous rulings of the Court which had held that such claims were actionable under Section 1983 if they were not adequately addressed by state law remedies. Furthermore, he pointed out that Nebraska law did not provide an adequate remedy in this case because it only allowed recovery up to $1,000 while Taylor’s hobby kit was worth more than $23.50 but less than $1,000; thus his loss would be total unless federal relief is available. Additionally, he criticized the majority's reliance on procedural due process principles as misplaced since those principles are designed to protect against arbitrary government action rather than negligent conduct by individual employees.