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Municipality may be Held Liable Under § 1983 only for its Own Violations of Federal Law, Irrespective of Whether Relief Sought is Monetary or Prospective
Municipality may be Held Liable Under § 1983 only for its Own Violations of Federal Law, Irrespective of Whether Relief Sought is Monetary or Prospective
In November 2010, a unanimous U.S. Supreme Court, overruling the Ninth Circuit, held that the nature of the relief sought does not change the requirement that, in order for civil rights plaintiffs to successfully sue a municipal entity (such as a county) under 42 U.S.C. § 1983, they must show that their injury was caused by the municipality's own custom, policy or practice.
The case arose when a Los Angeles couple was arrested on charges of child abuse but later found to be "factually innocent." The couple subsequently sought to have their names removed from California's Child Abuse Central Index, but could not do so because procedures did not then exist for an aggrieved party to contest inclusion in the Index.
The couple filed a § 1983 suit against the State Attorney General, the county and county officials seeking damages, an injunction and a declaration that the defendants had violated their constitutional rights by failing to create a procedural mechanism that would allow them to challenge their inclusion in the Index. The district court, holding that California had not deprived the couple of any constitutionally protected liberty interest, granted summary judgment to all of the defendants.
On appeal the Ninth Circuit disagreed, holding that the Due Process Clause of the Fourteenth Amendment required the state to provide notice and "some kind of hearing" to those included in the Index. Then appellate court entered declaratory judgment in favor of the couple and additionally held that, as prevailing parties, they were entitled to attorney's fees.
Los Angeles County challenged the latter holding, arguing to the Supreme Court that, as a municipality, it could be held liable for violations of federal law only if those violations were caused by its own customs, policies or practices. Indeed, the Supreme Court had so held in Monell v. NYC Dept. of Social Servs., 436 U.S. 658 (1978).
The Ninth Circuit, alone among the Circuits, had interpreted Monell’s holding to apply only in the context of claims for damages and not to claims for prospective relief. The Supreme Court categorically rejected that distinction, paving the way for the county to try to establish (on remand) that it was state policy – not county policy – that caused any injury that may have occurred. See: Los Angeles County v. Humphries, 131 S.Ct. 447 (2010).
In November 2010, a unanimous U.S. Supreme Court, overruling the Ninth Circuit, held that the nature of the relief sought does not change the requirement that, in order for civil rights plaintiffs to successfully sue a municipal entity (such as a county) under 42 U.S.C. § 1983, they must show that their injury was caused by the municipality's own custom, policy or practice.
The case arose when a Los Angeles couple was arrested on charges of child abuse but later found to be "factually innocent." The couple subsequently sought to have their names removed from California's Child Abuse Central Index, but could not do so because procedures did not then exist for an aggrieved party to contest inclusion in the Index.
The couple filed a § 1983 suit against the State Attorney General, the county and county officials seeking damages, an injunction and a declaration that the defendants had violated their constitutional rights by failing to create a procedural mechanism that would allow them to challenge their inclusion in the Index. The district court, holding that California had not deprived the couple of any constitutionally protected liberty interest, granted summary judgment to all of the defendants.
On appeal the Ninth Circuit disagreed, holding that the Due Process Clause of the Fourteenth Amendment required the state to provide notice and "some kind of hearing" to those included in the Index. Then appellate court entered declaratory judgment in favor of the couple and additionally held that, as prevailing parties, they were entitled to attorney's fees.
Los Angeles County challenged the latter holding, arguing to the Supreme Court that, as a municipality, it could be held liable for violations of federal law only if those violations were caused by its own customs, policies or practices. Indeed, the Supreme Court had so held in Monell v. NYC Dept. of Social Servs., 436 U.S. 658 (1978).
The Ninth Circuit, alone among the Circuits, had interpreted Monell’s holding to apply only in the context of claims for damages and not to claims for prospective relief. The Supreme Court categorically rejected that distinction, paving the way for the county to try to establish (on remand) that it was state policy – not county policy – that caused any injury that may have occurred. See: Los Angeles County v. Humphries, 131 S.Ct. 447 (2010).
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Related legal case
Los Angeles County v. Humphries
| Year | 2010 |
|---|---|
| Cite | 131 S.Ct. 447 (2010) |
| Level | Supreme Court |
| Conclusion | Bench Verdict |
| Injunction Status | N/A |