Cooper v. Pate: Summary, Facts & Ruling

Instructor: Kenneth Poortvliet

Kenneth has a JD, practiced law for over 10 years, and has taught criminal justice courses as a full-time instructor.

A plaintiff must have the lawful authority to bring a case before a court. In this lesson, we will discover how the Supreme Court decided in ''Cooper v. Pate'' if state prisoners had the right to file a case regarding prison conditions in a federal court.

We Can't Hear You

If you have a constitutional right that is being deprived by your government, would it seem fair if you filed a claim in federal court and the judge said you didn't have the right to bring the case in the first place? This is the issue the Supreme Court faced in Cooper v. Pate (1967).

Facts of the Case

Cooper, an inmate in the Illinois State Penitentiary, filed a complaint in Federal District Court alleging that his religious rights were being violated under federal law. While in prison, Cooper converted to Islam and alleged that he was denied access to the Quran, Islam's holy text, and other religious materials. He claimed that Christians were allowed Bibles, access to the chapel, and access other religious materials, while he was denied the same treatment.

The district court judge dismissed the complaint, and Cooper appealed to the 7th Circuit Court of Appeals. The circuit affirmed the dismissal, and Cooper appealed to the U.S. Supreme Court.

Historical Background

The American institution of justice is divided by a state and a federal system of laws and jurisdictions. A state case, which is a controversy between parties of a state, is completely within that state's jurisdiction and typically can't be heard in a federal court unless the issue was related to federal law. However, in 1868, the 14th Amendment was ratified, which extended many of the fundamental rights to the states. This allowed state citizens to sue their state in federal courts for a violation of their rights.

But which rights? The 14th Amendment's language included the equal protection clause, which required that the state government treat their citizens equally under the law. This allowed the federal courts to strike down state laws and practices that violated their own citizens' constitutional rights.

While this applied to state citizens across the land, it did not reach those in state prisons. In Ruffin v. Commonwealth in 1872, the Virginia Supreme Court held that ''prisoners are the slaves of the State undergoing punishment for heinous crimes committed against the laws of the land.'' Although this was not legally binding on the other states or the federal government, it was adopted by the Supreme Court and became the unofficial hands-off doctrine.

This meant that even though the 14th Amendment prohibited the state governments from discriminating against their citizens' religious rights, state prisoners were not protected because under the hands-off doctrine, a state prisoner had no rights, thus there could be not a violation of rights.


This case was appealed to the Supreme Court from an order of dismissal by the district court. This was affirmed by the Court of Appeals. The district court heard the allegations by Cooper and addressed them but ultimately ruled that there was no case because Cooper, being a state prisoner, failed to allege any rights violations that could be heard by the federal courts.

Likewise, the Court of Appeals reviewed the facts on the record from the trial court and affirmed the district court's dismissal. So even though the courts did not specifically cite the hands-off doctrine, they upheld the long-standing tradition of treating state prisoners as if they had no rights.

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