Los Angeles County v. Humphries (U.S. Supreme Court)

In Monell v. New York City Department of Social Services, 436 U.S. 658 (1978), the Supreme Court ruled that civil rights claims could only be made against a municipality under 42 U.S.C. 1983 if a violation resulted from the municipality’s policy or custom. We argued that the holding in Monell, a case where the plaintiffs sought money damages, should not apply in other cases where plaintiffs seek prospective relief such as declaratory judgments or injunctions. The Supreme Court held that Monell did apply to cases seeking prospective relief. Thus, the plaintiffs in Humphries could not gain relief without showing that their constitutional deprivation resulted from a municipal policy rather than specific actions performed by public officials.