Published Online: December 7, 2010
Published in Print: December 8, 2010, as Supreme Court Decision Limits Municipal Liability

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Supreme Court Decision Limits Municipal Liability

Case Involved Teacher Listed on Abuse Registry

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In a decision with implications for school districts, the U.S. Supreme Court last week strengthened protections against municipal liability in federal civil rights lawsuits.

The justices ruled 8-0 in Los Angeles County v. Humphries that a 1978 high court decision about municipal liability for civil rights violations applies even when a plaintiff is seeking only an injunction or a declaratory judgment, in contrast to monetary damages.

The Nov. 30 decision comes in the case of a California teacher and her husband who were wrongfully accused of child abuse and discovered after they were exonerated that they had no way to remove their names from a state child-abuse registry. They sued Los Angeles County and its sheriff, as well as the state, alleging a violation of their 14th Amendment right to due process of law.

The older Supreme Court decision, Monell v. New York City Department of Social Services, held that cities, counties, and school districts could only be found liable when a civil rights plaintiff could show that a violation stemmed from a municipal policy or custom, as opposed to the government agency simply being the employer of the rights violator. School districts, for example, are often sued over the actions of their employees, but the plaintiffs often find it difficult to prove an action was the result of a district policy or custom. The new decision applies the Monell standard to a broader category of claims.

The Monell case involved monetary damages, and the issue in the Humphries case was whether the policy or custom requirement also extended to when plaintiffs sought only prospective relief, such as an injunction or other court order.

Writing for every member of the court except Justice Elena Kagan, who was recused, Justice Stephen G. Breyer said that it “would undermine Monell’s logic” if the policy or custom requirement was not also applied to the broader category of civil rights cases.

The case arose from what a lower court called a “parents’ nightmare,” in which Craig and Wendy Humphries found that there was no procedure for removing their names from the state child-abuse index, despite a court declaration that cleared them of the abuse charges. Among the difficulties the couple faced, court papers said, was that Ms. Humphries’ inclusion on the child-abuse index threatened her ability to remain licensed as a special education teacher.

The high courts ruling appeared to leave undisturbed part of a lower courts decision that required the state of California to develop some form of hearing for those who seek to challenge their inclusion on the state child-abuse registry.

Vol. 30, Issue 14, Page 5

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