Los Angeles County v. Humphries
The Supreme Court ruled that the same rule limiting when cities and counties can be sued under federal civil rights law applies no matter what kind of relief a plaintiff is seeking — whether it's money damages or a court order.
The decision resolves a split among lower courts and means that people suing a local government for an injunction or declaratory judgment, not just damages, must still show the local government's own policy or custom caused their injury.
“Nothing in the text of § 1983 suggests that the causation requirement contained in the statute should change with the form of relief sought.”
The Court explains why the same liability rule applies whether a plaintiff seeks money or a court order.
How it got here: A federal trial court ruled for the officials; the Ninth Circuit reversed in part and ordered declaratory relief and attorney's fees; the county asked the Supreme Court to review whether Monell's limits apply to non-damages claims.
The Case in Depth
What happened
Two people were falsely accused of child abuse, listed in California's statewide Child Abuse Central Index, and later cleared. California law did not let them challenge or remove their names from the list. They sued California's attorney general, Los Angeles County, its sheriff, and two detectives, seeking money damages, an injunction, and a declaration that officials had violated their constitutional rights by providing no way to contest the listing.
The question before the Court
When people sue a county for violating their rights but ask only for a court order or declaration — not money — does the county still have to be shown to have a specific policy or custom that caused the harm?
Why it matters
People who sue cities, counties, or other local governments over ongoing constitutional violations — not just past harm — will now have to prove the same thing everywhere in the country: that a specific government policy or custom, not just an individual employee's misconduct, caused the problem. That makes it somewhat harder to get injunctions or declarations against local governments in circuits that previously allowed such suits without that showing.
What changes now
The case goes back to the lower courts, where the county's liability must be reassessed under the correct legal standard — meaning the plaintiffs must show a county policy or custom, not just a state-created gap in procedures, caused their listing in the abuse index. The related dispute over roughly $60,000 in attorney's fees the county was ordered to pay will also need to be revisited in light of this ruling.
What this does not decide
The Court did not decide whether Los Angeles County actually had a policy or custom that caused the plaintiffs' harm, nor whether the plaintiffs' underlying constitutional rights were violated. Those questions were left for further proceedings on remand.
How the Court got there
The legal reasoning, step by step
- The Court applied its 1978 decision in Monell v. New York City Dept. of Social Servs., which held that a city or county can only be sued under the federal civil rights law, 42 U.S.C. § 1983, if the government's own policy or custom — not just an employee's individual wrongdoing — caused the harm.
- The Court examined the wording of § 1983 itself, which says a person who causes a deprivation of rights is liable 'in an action at law, suit in equity, or other proper proceeding for redress' — language that draws no distinction between damages suits and suits seeking an injunction or declaration.
- The Court reasoned that Monell's core idea was about whose conduct counts as the government's 'own' wrongdoing, which depends on the nature of the conduct at issue, not on what kind of court remedy the plaintiff later requests.
- The Court rejected the argument that Monell's policy-or-custom rule was really about protecting government treasuries from large damages awards, explaining that Monell's real concern was distinguishing a government's own violations from the violations of its employees acting alone.
- Because nothing about seeking an injunction or declaration changes whose conduct is at issue, the Court concluded that the policy-or-custom requirement applies equally to claims for prospective relief and claims for damages.
Doctrinal impact
Cases affected by this decision
Reaffirms Monell (436 U.S. 658)
The Court relies on and extends Monell's policy-or-custom rule to cover claims for injunctions and declarations, not just damages.