McMillian v. Monroe County

Background

A man who had been convicted of murder and spent nearly six years on Alabama’s death row sued Monroe County and local officials under the federal civil-rights law, 42 U.S.C. §1983. The Alabama Court of Criminal Appeals later reversed his conviction after finding officials had hidden evidence, and he was released. He then sued the sheriff and others, alleging intimidation of a witness and suppression of exculpatory evidence; lower courts dismissed the county liability claims and the Eleventh Circuit affirmed, leading to Supreme Court review.

Reasoning

The central question was whether a county sheriff, when acting in law-enforcement matters, speaks for the county or for the State. The majority examined Alabama’s Constitution, statutes, historical practice, and state-court decisions. It concluded that, for the duties at issue, Alabama sheriffs are state officers who enforce state criminal law and answer to state officials in key respects. Relying on that state-law analysis and earlier federal cases about municipal liability, the Court held the sheriff represented the State, so Monroe County could not be held liable under §1983 for those law-enforcement actions.

Real world impact

The ruling means people suing counties in Alabama for sheriffs’ law-enforcement misconduct may not be able to hold the county responsible; plaintiffs can still pursue individual officers in their personal capacities. The decision also notes that sheriffs may be county policymakers for other functions (for example, running a county jail) and that outcomes will turn on each State’s law, so results can differ across States.

Dissents or concurrances

The dissent argued the sheriff is essentially a county official — locally elected, paid, and equipped — and contended the majority misreads Alabama law, so counties should sometimes be answerable under §1983.