In the case of Tom Swint, et al. v. Chambers County Commission, et al., 1994, the U.S Supreme Court dealt with issues related to qualified immunity and municipal liability under Section 1983 of Title 42 of the United States Code. The plaintiffs alleged that a county sheriff's department had violated their Fourth Amendment rights during an arrest operation by using excessive force and failing to provide medical care promptly. The Eleventh Circuit Court ruled in favor of the plaintiffs on both counts but granted qualified immunity to individual officers involved in the incident while holding that Sheriff Swint could be held liable for his deputies' actions as he was their final policymaker. The Supreme Court reversed this decision stating that it was inappropriate for lower courts to assume without deciding whether or not a government official is a final policymaker because such determinations are necessary prerequisites for establishing municipal liability under Section 1983. Furthermore, they found no evidence supporting claims against Sheriff Swint personally nor any policy or custom leading to constitutional violations within his department which would warrant imposing municipal liability on him or Chambers County.

In the dissenting opinion for Tom Swint, et al. v. Chambers County Commission, et al., Justice Ginsburg disagreed with the majority's decision to dismiss all claims against Sheriff Morgan and Deputy Sheriff Cotney due to lack of jurisdiction. She argued that there was enough evidence presented at trial to suggest that both officers may have been acting under a county policy when they allegedly violated Swint's constitutional rights during his arrest. Therefore, she believed it would be more appropriate for a jury to decide whether or not these actions were taken as part of an official county policy rather than dismissing them outright on jurisdictional grounds.