Butz v. Economou
**Overview of Butz v. Economou**
Butz v. Economou is a significant legal case that addresses the issue of executive immunity for government officials. The case arose when commodities dealer Economou filed a $32 million civil suit against Earl Butz, the Secretary of Agriculture, alleging that Butz had made a false claim against him in retaliation for Economou's criticisms of the department's policies. The central question was whether Butz could claim absolute immunity from the lawsuit. In a 5-4 decision, the Supreme Court, led by Chief Justice Byron R. White, ruled that executive officials are entitled to qualified good-faith immunity rather than absolute immunity. This means that officials can be held accountable for damages if their actions violate clearly established rights or if they act with malicious intent to harm an individual. The ruling also specified that there are exceptions for prosecutors and judicial officials within administrative agencies. This case has had lasting implications on the legal standards governing the accountability of government officials in the United States.
Butz v. Economou
Date: June 29, 1978
Citation: 438 U.S. 478
Issue: Executive immunity
Significance: The Supreme Court held that high officials of the executive branch, with rare exceptions, do not have absolute immunity from civil suits.
Economou, a commodities dealer, filed a civil suit for $32 million, claiming that Secretary of Agriculture Butz had entered a false claim against him because of his criticisms of the department’s policies. Citing Supreme Court precedents, Butz responded that he had absolute immunity from such a suit. Speaking for a 5-4 majority, however, Chief Justice Byron R. White declared that executive officials are entitled only to qualified good-faith immunity. Thus, officials are liable for damages if their illegal actions actually deprived a person of clearly established rights or if they acted with malicious intention in an attempt to cause harm or to deprive a person of constitutional rights. The Court allowed for exceptions for prosecutors and judicial officials within administrative agencies.
In Harlow v. Fitzgerald (1982), the Court modified the Economou ruling by eliminating the malicious intention test as a basis for bringing suits against officials. In Harlow’s companion case, Nixon v. Fitzgerald (1982), the Court found that the president did have absolute immunity for any actions stemming from his official duties.