Los Angeles County v. Humphries
Encyclopedia
Los Angeles County v. Humphries, 562 U.S. ___ (2010), is a decision by the Supreme Court of the United States
that clarified one of the requirements for imposing liability on a municipality
for violations of a federal right, in lawsuits brought under Section 1983 of the Civil Rights Act of 1871
(codified at ).
The Court had previously ruled in Monell v. New York City Dept. of Social Servs., , that municipalities could only be liable under Section 1983 if the injury was a result of that municipality's "policy or custom." In Los Angeles County v. Humphries, the Court ruled that this "policy or custom" requirement applied regardless of whether the relief the plaintiff sought was monetary or prospective.
In Monroe v. Pape
, 365 U.S. 167 (1961), the Supreme Court had held that municipal entities were not "person[s]" under §1983, based on its reading of the history of the Civil Rights Act of 1871
. However, the Court overruled Monroe in Monell v. New York City Dept. of Social Servs., , holding that municipalities were "persons" under §1983, but that a municipality could be held liable under §1983 only for its own violations of federal law. The violation must be caused by the "execution of [the municipality's] policy or custom", not simply when others have caused the violation such as if the municipality "employ[ed] a tortfeasor."
Two parents who were accused of child abuse but exonerated sought to have their names removed from the Index but were unable to convince the Los Angeles Sheriff’s Department to remove them. They consequently filed a §1983 case against the Attorney General of California, the Los Angeles County Sheriff, two detectives in the sheriff’s department, and the County of Los Angeles, seeking damages, an injunction, and a declaration that the defendants had deprived them of their constitutional rights by failing to create a procedural mechanism through which one could contest inclusion in the Index.
The Ninth Circuit held in favor of the plaintiffs. Los Angeles County appealed, arguing that it was not liable because, with respect to the county, the plaintiffs were not prevailing parties because the county was a municipal entity. It argued that under Monell’s holding, a municipal entity is liable under §1983 only if a municipal "policy or custom" caused a plaintiff to be deprived of a federal right and it was state policy, not county policy, that brought about any deprivation here.
, the Court concluded that Monells holding applied to §1983 claims against municipalities for prospective relief as well as to claims for damages.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
that clarified one of the requirements for imposing liability on a municipality
Municipality
A municipality is essentially an urban administrative division having corporate status and usually powers of self-government. It can also be used to mean the governing body of a municipality. A municipality is a general-purpose administrative subdivision, as opposed to a special-purpose district...
for violations of a federal right, in lawsuits brought under Section 1983 of the Civil Rights Act of 1871
Civil Rights Act of 1871
The Civil Rights Act of 1871, , enacted April 20, 1871, is a federal law in force in the United States. The Act was originally enacted a few years after the American Civil War, along with the 1870 Force Act. One of the chief reasons for its passage was to protect southern blacks from the Ku Klux...
(codified at ).
The Court had previously ruled in Monell v. New York City Dept. of Social Servs., , that municipalities could only be liable under Section 1983 if the injury was a result of that municipality's "policy or custom." In Los Angeles County v. Humphries, the Court ruled that this "policy or custom" requirement applied regardless of whether the relief the plaintiff sought was monetary or prospective.
Section 1983 of the 1871 Civil Rights Act
Section 1983 provides in part:- "Every person who, under color of any [state] statute, ordinance, regulation, custom, or usage . . . subjects, or causes to be subjected, any ... other person ... to the deprivation of any rights ... secured by the Constitution and laws [of the United States], shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress."
In Monroe v. Pape
Monroe v. Pape
Monroe v. Pape, , was a United States Supreme Court case that considered the application of Federal Civil Rights law to constitutional violations by city employees.- Background :...
, 365 U.S. 167 (1961), the Supreme Court had held that municipal entities were not "person[s]" under §1983, based on its reading of the history of the Civil Rights Act of 1871
Civil Rights Act of 1871
The Civil Rights Act of 1871, , enacted April 20, 1871, is a federal law in force in the United States. The Act was originally enacted a few years after the American Civil War, along with the 1870 Force Act. One of the chief reasons for its passage was to protect southern blacks from the Ku Klux...
. However, the Court overruled Monroe in Monell v. New York City Dept. of Social Servs., , holding that municipalities were "persons" under §1983, but that a municipality could be held liable under §1983 only for its own violations of federal law. The violation must be caused by the "execution of [the municipality's] policy or custom", not simply when others have caused the violation such as if the municipality "employ[ed] a tortfeasor."
Lower court proceedings
The California Child Abuse and Neglect Reporting Act required law enforcement and other state agencies to investigate allegations of child abuse, report all instances of reported child abuse the agency found “not unfounded” to the California Department of Justice, even if they were "inconclusive or unsubstantiated", and required the department to include the reports in a Child Abuse Central Index. However, the Act did not provide procedures for reviewing whether a previously filed report was unfounded or for allowing individual people to challenge their inclusion in the index.Two parents who were accused of child abuse but exonerated sought to have their names removed from the Index but were unable to convince the Los Angeles Sheriff’s Department to remove them. They consequently filed a §1983 case against the Attorney General of California, the Los Angeles County Sheriff, two detectives in the sheriff’s department, and the County of Los Angeles, seeking damages, an injunction, and a declaration that the defendants had deprived them of their constitutional rights by failing to create a procedural mechanism through which one could contest inclusion in the Index.
The Ninth Circuit held in favor of the plaintiffs. Los Angeles County appealed, arguing that it was not liable because, with respect to the county, the plaintiffs were not prevailing parties because the county was a municipal entity. It argued that under Monell’s holding, a municipal entity is liable under §1983 only if a municipal "policy or custom" caused a plaintiff to be deprived of a federal right and it was state policy, not county policy, that brought about any deprivation here.
The Court's decision
In an 8-0 decision delivered by Justice Stephen BreyerStephen Breyer
Stephen Gerald Breyer is an Associate Justice of the U.S. Supreme Court. Appointed by President Bill Clinton in 1994, and known for his pragmatic approach to constitutional law, Breyer is generally associated with the more liberal side of the Court....
, the Court concluded that Monells holding applied to §1983 claims against municipalities for prospective relief as well as to claims for damages.