Maine v. United States Environmental Protection Agency

How later courts describe this case

• concluding that reckless conduct can trigger the protections of the Due Process Clause, but that gross negligence cannot
• deciding that even assuming a violation of state statutes, no § 1983 action can be ensued based solely on that basis
• fire department dispatcher’s refusal to send rescue squad after two requests by telephone was not reckless in the constitutional sense so as to support a section 1983 action
• “A person is reckless or acts recklessly, when he consciously disregards a substantial and unjustifiable risk that circumstances exist or that a result will follow.”
• illegality of official action under state statute can neither add to nor subtract from its constitutional validity
• no § 1983 liability for failure to provide requested emergency services
• "An act is reckless in the pertinent sense when it reflects complete indifference to risk--when the actor does not care whether the other person lives or dies, despite knowing that there is a significant risk of death."
• “A statement that logically refers to a particular person may be actionable.”