Term: 2010
Docket: 09-350
Los Angeles County, California, Petitioner v. Craig Arthur Humphries Et Al.
- Pro
09-350 LOS ANGELES COUNTY V. HUMPHRIES DECISION BELOW: CTA 9 order JUSTICE KAGAN TOOK NO PART CERT. GRANTED 2/22/2010 QUESTION PRESENTED: 1. Are claims for declaratory relief against a local public entity subject to the requirement of Monell v. Department of Social Services, 436 U.S. 658 (1978) that the plaintiff demonstrate that the constitutional violation was the result of a policy, custom or practice attributable to the local public entity as determined by the First, Second, Fourth and Eleventh Circuits, or are such claims exempt from Monell's requirement as determined by the Ninth Circuit? 2. May a plaintiff be a prevailing party under 42 U.S.C. §1988 for purposes of a fee award against a local public entity based upon a claim for declaratory relief where the plaintiff has not demonstrated that any constitutional violation was the result of a policy, custom or practice attributable to the public entity under Monell? 3. May a plaintiff be a prevailing party on a claim for declaratory relief for purposes of a fee award under 42 U.S.C. §1988 where there is neither a formal order nor judgment granting declaratory relief, nor any other order altering the legal relationship between the parties in a way that directly benefits the plaintiff? LOWER COURT CASE NUMBER: 05-56467
In the case of Los Angeles County, California v. Craig Arthur Humphries et al., 2010, the U.S. Supreme Court ruled that a county could be held liable for failing to provide due process in maintaining a child abuse registry. The case involved Craig and Wendy Humphries who were falsely accused of abusing their daughter and subsequently cleared of all charges; however, their names remained on California's Child Abuse Central Index (CACI). They sued Los Angeles County under Section 1983 claiming violation of their constitutional rights by not providing them with an opportunity to clear their names from CACI. Initially, lower courts dismissed the suit against LA County stating it was immune from such lawsuits under the Eleventh Amendment but held state officials accountable for violating plaintiffs' right to due process. However, upon reaching Supreme Court it reversed this decision holding that counties are "persons" who can be sued under Section 1983 if they violate someone's constitutional rights while acting under color of any statute or regulation.
In the dissenting opinion for Los Angeles County, California v. Craig Arthur Humphries et al., Justice Scalia argued that the majority's decision to allow a claim against Los Angeles County under Section 1983 was incorrect because it ignored precedent and misinterpreted Monell v. Department of Social Services of City of New York (1978). He contended that in order to establish liability under Section 1983, there must be proof that an unconstitutional action was taken by a municipal employee according to official municipal policy or custom. In this case, he believed such evidence did not exist as the county had no control over state-mandated child abuse reporting procedures and thus could not be held responsible for any constitutional violations arising from them. Furthermore, he criticized the majority’s reliance on Pembaur v Cincinnati (1986), arguing it only applied when a single act constituted official policy – which wasn't applicable here since multiple decisions were involved.
