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Qualified Immunity Civil Rights

Monell

436 U.S. 658Supreme Court of the United States1978Date unavailable

Summary

In Monell, the Supreme Court overruled part of Monroe v. Pape and held that local governments are 'persons' under § 1983. Municipalities may be liable when official policy or custom causes a constitutional violation, but not simply because they employ the person who committed the violation.

Legal Issue

Are local governments and local officials sued in their official capacities 'persons' subject to suit under 42 U.S.C. § 1983, and may they be liable for constitutional violations caused by official policy or custom?

Holding

Yes. The Supreme Court held that local governments are 'persons' under § 1983 and may be sued for monetary, declaratory, or injunctive relief when an unconstitutional action implements official policy, regulation, decision, or custom. But a municipality is not liable merely because it employs someone who committed a constitutional tort; respondeat superior does not apply.

Rule of Law

A city can be sued under § 1983 when its own policy or custom causes a constitutional violation. But the city is not automatically responsible for every unconstitutional act by one employee.

Court Reasoning

Not yet summarized.

Impact for Officers

Monell remains central in police-misconduct and civil-rights litigation. Plaintiffs often use it to challenge agency policies, training, supervision, discipline, or recurring customs. Agencies use it as a reminder that written policy, real-world practice, and training records can determine whether a case is only about an individual officer or about the government itself.

What Officers Can Do

Not yet summarized.

What Officers Should Avoid

Not yet summarized.

Common Misunderstanding

Not yet summarized.