Butz v. Economou - Significance
department administrative officials agriculture
While the decision in Butz v. Economou limited the immunity entitled to federal executive officials for constitutional violations, it also extended absolute immunity to various judicial and administrative officials within federal agencies.
Arthur N. Economou was the head of a commodity futures commission company. On 19 February 1970, following an audit, the United States Department of Agriculture issued an administrative complaint alleging that Economou had willfully failed to maintain the minimum financial requirements set down by the department. The Department of Agriculture then tried, unsuccessfully, to revoke the company's registration in an administrative proceeding. Afterwards, Economou filed for damages in district court against several U.S.D.A. officials, including the secretary and assistant secretary of agriculture, the judicial officer, the chief hearing examiner who had recommended sustaining the administrative complaint, and the department attorney who had prosecuted the enforcement proceeding. He claimed that by initiating unauthorized proceedings against him they had violated his constitutional rights.
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