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United States Fourth Circuit

Manning v. Caldwell, 17-1320

Rejected a constitutional challenge to Virginia's interdiction statute, under which a person can be civilly designated a habitual drunkard and subject to restrictions on using or possessing alcohol. Four homeless people suffering from alcoholism who each had been prosecuted at least eleven times for violating their interdiction orders challenged the statute's constitutionality under the Eighth Amendment's prohibition on criminalizing status, and the Fourteenth Amendment's guarantee of Due Process and Equal Protection. Affirming dismissal of their putative class action, the Fourth Circuit held that they failed to state a claim.

Appellate Information

  • Decided
  • Published 2018/08/09


  • Wilkinson


  • United States Fourth Circuit


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