Walters v. McMahen

What This Case Is About

Walters v. McMahen is a RICO conspiracy case, not a § 1983 civil rights case. However, it is significant in § 1983 litigation because it applies the intracorporate conspiracy doctrine—the principle that employees of the same entity cannot conspire with each other when acting within the scope of their employment. This doctrine is frequently invoked in § 1983 cases to defeat conspiracy claims against multiple officers or employees of the same police department or municipality.

The Facts

Plaintiffs Bizzie Walters, Annie Hodge, and others filed a class action against twenty-nine current and former Perdue Farms employees. They alleged that the defendants—mid-level human resources managers and staff—conspired to depress the wages of legal, hourly-paid employees by hiring and falsely attesting to the work authorization of large numbers of illegal immigrants, in violation of RICO.

The plaintiffs claimed that corporate management directed HR managers to accept false documents from illegal immigrants and to falsely attest to their authenticity. They alleged that these practices were pervasive across Perdue’s processing facilities nationwide, saving the company millions in labor costs while depressing wages for legally authorized workers.

The defendants moved to dismiss, arguing that the complaint failed to state a plausible claim under Twombly and Iqbal and that the intracorporate conspiracy doctrine barred the conspiracy claims.

What the Court Decided

The court granted the motion to dismiss with prejudice on multiple grounds.

First, the court held that the plaintiffs’ RICO theory was implausible. The claim that mid-level HR employees conspired to enrich themselves by causing Perdue to hire illegal immigrants—thereby increasing net profit, which would supposedly increase the potential for higher salaries—was too speculative and attenuated to state a plausible claim.

Second, and most importantly for § 1983 purposes, the court applied the intracorporate conspiracy doctrine. Under this doctrine, a corporation cannot conspire with its own employees, and employees of the same corporation, when acting within the scope of their employment, cannot conspire among themselves. The court found that all named defendants were Perdue employees acting within the scope of their HR duties, and therefore could not form a RICO conspiracy as a matter of law.

The court noted that exceptions to the intracorporate conspiracy doctrine exist—such as when employees act for purely personal motives independent of their employment—but found no such exception applied here.

Why This Case Matters for Your § 1983 Case

The intracorporate conspiracy doctrine applies to § 1983. When you allege that multiple officers from the same police department conspired to violate your rights, defendants will invoke this doctrine. Under it, officers of the same governmental entity cannot conspire with each other when acting within the scope of their official duties.

Exceptions exist but are narrow. If officers were acting outside the scope of their employment—pursuing purely personal objectives—the intracorporate conspiracy doctrine may not apply. Similarly, some circuits recognize exceptions when officers are motivated by personal racial animus independent of their official duties.

Conspiracy claims require specific factual allegations. Beyond the intracorporate doctrine, conspiracy claims under § 1983 require you to allege specific facts showing an agreement between defendants—not just that they were present or acted in similar ways. Parallel conduct is not enough.

Plausibility matters for conspiracy claims. The court’s rejection of the plaintiffs’ attenuated theory of harm illustrates that conspiracy claims must be grounded in plausible factual allegations, not speculative chains of causation.

Key Takeaway

Walters v. McMahen reinforces the intracorporate conspiracy doctrine, which presents a significant obstacle for § 1983 plaintiffs alleging that officers from the same department conspired to violate their rights. To overcome this doctrine, plaintiffs must show that the officers were acting outside the scope of their employment or were motivated by purely personal objectives independent of their official duties.