November 30, 2010

Supreme Court Decides Los Angeles County v. Humphries

On November 30, 2010, the Supreme Court decided Los Angeles County v. Humphries, No. 09-350, holding that a municipal entity can be held liable under 42 U.S.C. §1983 only if its own "policy or custom" caused the violation of a plaintiff's federal right, regardless of whether the relief sought is monetary, injunctive, or declaratory.

 

In Monell v. New York City Dept. of Social Services, 436 U.S. 658 (1978), the Court had held that civil rights plaintiffs suing a municipal entity under §1983 must show that their injury was caused by the municipality's own policy or custom, because a municipality may be held liable only for its own violations, not the violations of some other entity. Because the plaintiff in Monell sought damages and not forward-looking relief such as an injunction or declaration, a question arose whether its rule extended to such relief. Since 1989, the Ninth Circuit has held that Monell applies only to claims for monetary relief, while other circuits have applied Monell more broadly.

 

The Humphries sued Los Angeles County, among other entities, for monetary, injunctive, and declaratory relief.  The Humphries were accused of child abuse by one of their children but later exonerated when a doctor confirmed that the abuse charges could not be true. Under a California statute, however, law enforcement officials who investigate such allegations must include their reports in a statewide Child Abuse Central Index if the allegations are "not unfounded" even if they are "inconclusive or unsubstantiated." The Humphries' names remained on the Index, available to a wide array of government agencies, employers, and law enforcement agencies, for years, without any procedure that would allow them to challenge their inclusion in the Index. They sued Los Angeles County and others under §1983 and won the right to challenge their inclusion, plus attorneys' fees, in the Ninth Circuit. Los Angeles County challenged its portion of the award of attorneys' fees in the Supreme Court.

 

The Supreme Court reversed the fee award against Los Angeles County, holding that in all cases brought under §1983, a municipal entity may be held liable only for its own policy or custom, regardless of the relief sought. The Court explained:

 

The Monell Court thought that Congress intended potential §1983 liability where a municipality's own violations were at issue but not where only the violations of others were at issue.  The "policy or custom" requirement rests upon that distinction and embodies it in law.  … [W]hether an action or omission is the municipality's "own" has to do with the nature of the action or omission, not with the nature of the relief that is later sought in court.

 

More broadly, the Court rebuffed the plaintiffs' attempts to limit Monell's holding to the precise facts of that case.  The Court explained that a holding "can extend through its logic beyond the specific facts of the particular case." 

 

Justice Breyer delivered the opinion for a unanimous Court.  Justice Kagan took no part in the consideration or decision of the case.

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