Los Angeles County, CA v. Humphries

PETITIONER: Los Angeles County, CA
RESPONDENT: Craig Arthur Humphries et al.
LOCATION: U.S. Capitol Building

DOCKET NO.: 09-350
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Ninth Circuit

CITATION: 562 US 29 (2010)
GRANTED: Feb 22, 2010
ARGUED: Oct 05, 2010
DECIDED: Nov 30, 2010

ADVOCATES:
Andrew J. Pincus - for the respondents
Timothy T. Coates - for the petitioner

Facts of the case

Craig and Wendy Humphries were accused of abuse by one of their children, arrested, and their children were taken away from them. They were charged with child abuse and felony torture, but the charges were dismissed once it became clear the allegations were not true. Despite the fact that the charges were dismissed, the Humphries were placed on California's Child Abuse Central Index ("CACI") – a database for known and suspected child abusers. The Humphries subsequently filed suit against Los Angeles County and various County officials in a California federal district court. The Humphries argued that California's maintenance of the CACI violates the Due Process Clause of the Fourteenth Amendment because identified individuals are not given fair opportunity to challenge the allegations against them. The district court dismissed their claims.

On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed holding that the erroneous listing of the Humphries on the CACI violated the Due Process Clause of the Fourteenth Amendment. The Humphries, as the prevailing party, then moved for attorneys' fees. The Ninth Circuit awarded the fees, reasoning that the limitations to liability established in Monell v. Department of Social Services do not apply to claims for declaratory relief.

Question

Are claims for declaratory relief against a local public entity subject to the requirement of Monell that the plaintiff must demonstrate that the constitutional violation was the result of the policy, custom, or practice attributable to the local public entity; or are such claims exempt as determined by the Ninth Circuit?

Media for Los Angeles County, CA v. Humphries

Audio Transcription for Oral Argument - October 05, 2010 in Los Angeles County, CA v. Humphries

Audio Transcription for Opinion Announcement - November 30, 2010 in Los Angeles County, CA v. Humphries

Stephen G. Breyer:

The basic civil rights statute 42 U.S.C. Section 1983 says “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 right 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.”

It's a basic text.

In 1961, this Court, in the case called “Monroe versus Pape” held that that statute, the text I read, did not apply to the actions of cities or towns or other municipalities.

But 16 years later, in another case called “Monell”, the New York City Department of Social Services, the Court reconsidered the question of municipal liability under Section -- Sections 1983 and it overruled Monroe.

In doing so, it held municipalities are persons who can be held liable under Section 1983.

But they can be held liable only for their own actions.

They cannot be held by vicariously liable for the actions of others, say their employees.

Now, I'll repeat that, that's the key point.

The Court expressly said, a “municipality cannot be held liable” solely for the acts of others, solely because it employs a tortfeasor.

But a municipality can be held liable for its own actions, namely, when execution of a government policy or custom inflicts the injury.

That's the basic rule.

The Ninth Circuit and has held that this municipality liability requirement, the policy or custom requirement, does apply when a plaintiff sues a municipality for damages but they've also held that the policy or custom requirement does not apply when a plaintiff seeks injunctive or other perspective relief looking to the future.

So, that's the cast question before us.

We look at this last holding, are they right to make this exception for perspective relief?

In our view, the Ninth Circuit's exception to the ordinary policy or custom requirement is wrong.

It has no basis in law.

Monell, referring to earlier cases, said specifically that its interpretation of the statute should not “have a bifurcated application to municipal corporations depending on the nature of the relief sought”.

Monell's logic and reasoning lead to exactly the same conclusion.

There is no difference, whether it's perspective relief or whether it's a monetary relief that they seek.

All the other Circuits who've decided the question have come to the same conclusion.

And for these reasons, which we explain more fully in our opinion, we conclude that Monell's policy or custom requirement applies in Section 1983 cases, whether the relief sought is monetary or whether it is perspective.

And we reverse the Ninth Circuit's contrary determination.

The decision is unanimous.

Justice Kagan took no part in the consideration or decision of the case.