The U.S. Supreme Court case County of Imperial, California, et al. v. Munoz et al., 1980 revolved around the issue of whether a county could be held liable under federal law for actions taken by its sheriff's department that allegedly violated an individual's civil rights. The plaintiffs in this case were individuals who had been arrested and detained by the Imperial County Sheriff's Department; they claimed their constitutional rights had been violated during these incidents and sought damages from both the officers involved and the county itself under Section 1983 of Title 42 of the United States Code (a statute allowing private citizens to sue government officials for violations of their constitutional rights). However, citing a previous ruling (Monell v. New York City Dept. Of Social Services), which stated that local governments are only liable under Section 1983 when it is proven that their official policies or customs caused a violation of someone’s constitutional rights, not simply because they employ a wrongdoer, the court ruled in favor of Imperial County.

In the dissenting opinion for County of Imperial, California, et al. v. Munoz et al., Justice William H. Rehnquist disagreed with the majority's decision that a county could not require its employees to reside within its borders as a condition of employment. He argued that such requirements were not unconstitutional and did not violate an individual’s right to travel or freedom of movement under the Privileges and Immunities Clause of Article IV or under any other provision in the Constitution. According to him, residency requirements are reasonable conditions imposed by local governments on their employees because they ensure availability during emergencies and foster community ties between public servants and those they serve.