Los Angeles County v. Humphries

Background

Two people who had been accused of child abuse but later cleared tried to get their names removed from California’s Child Abuse Central Index, a database that keeps reports for at least ten years. State law required agencies to report suspected abuse and did not set up procedures for challenging or removing entries, and no county procedures existed. The exonerated people sued the state attorney general, county officials, two detectives, and the County of Los Angeles under a federal civil-rights law, seeking money, a court order to change procedures, and a declaration that their rights were violated. The district court ruled for the officials, but the Ninth Circuit ordered a declaratory judgment and awarded attorney’s fees, concluding people on the list must get notice and a hearing and that Monell’s limits did not apply to court orders.

Reasoning

The Court considered whether the Monell rule—that a municipality is liable only when a city or county policy or custom caused a constitutional injury—also applies when plaintiffs ask for prospective relief like injunctions or declarations. The opinion reviewed the statutory text and Monell’s history and concluded the law’s causation requirement does not change depending on the remedy sought. The Court rejected arguments that Monell was limited to damages or that applying it here would leave violations unaddressed. It reversed the Ninth Circuit and sent the case back for further proceedings consistent with its ruling.

Real world impact

The decision means people seeking court orders against cities or counties must usually show a local policy or custom caused the problem. That requirement can make it harder to force changes and can affect whether municipalities owe attorney’s fees. The ruling is not a final decision on the underlying inclusion in the index; the case returns to lower courts for further proceedings.

Dissents or concurrances

Justice Kagan did not take part in the case’s consideration or decision.