City of St. Louis v. Praprotnik

Background

James H. Praprotnik, a longtime city architect, testified in 1980 and 1981 about personnel rules and a controversial public sculpture. After favorable early evaluations, he was suspended, won an appeal, then faced poorer ratings, a transfer to a lower-level assignment, and eventual layoff that a jury found retaliatory. At trial the jury cleared the three named supervisors yet found the city liable on the First Amendment claim; the Court of Appeals affirmed that finding before this Court reviewed the municipal-liability question.

Reasoning

The Court addressed when a city itself can be sued under the federal civil-rights law that allows people to sue governments for constitutional violations (42 U.S.C. §1983). The majority said a city is liable only if the constitutional injury resulted from an official municipal policy, a "custom or usage" with force of law, or a decision by an official who had final policymaking authority under state law. The Court emphasized prior decisions Monell and Pembaur and kept the long-standing "custom or usage" exception, rejecting efforts to treat all subordinate misconduct as city policy. The Court also stressed that identifying who can set official policy is governed by state law and that isolated acts by subordinate employees normally do not bind the city. The majority did not decide whether the employee ultimately proved his First Amendment claim on the facts.

Real world impact

The ruling sent the case back to the appeals court for further review under the clarified standard. Practically, workers alleging retaliation must show that a city policy, an entrenched custom, or a final policymaker’s decision caused their harm. The Court remanded the case for further proceedings and did not rule on whether the employee’s speech claim succeeded on the record. Lower courts must now apply state law to identify who may speak for the city.

Dissents or concurrances

Justice Brennan joined the judgment to reverse but warned the Court’s new formulations were too narrow. Justice Stevens dissented, arguing the record showed cooperation by top officials that should make the city liable.