## Facts

- Ronald Heller was stopped by Los Angeles police officers who suspected he was driving while intoxicated and was told he was under arrest.
- During an attempt to handcuff Heller, an altercation occurred and Heller fell through a plate-glass window.
- Heller sued under 42 U.S.C. § 1983, alleging (1) arrest without probable cause and (2) excessive force.
- At trial, the claims against the individual officer were tried first; the jury was instructed to find for Heller only if it found an arrest without reasonable cause or the use of unreasonable force.
- The jury returned a verdict for the officer; based on that result, the district court dismissed the claims against the City of Los Angeles and Police Commission members.
- The Ninth Circuit affirmed the officer’s verdict but reversed the municipal dismissal, reasoning the jury could have relied on a good-faith type rationale that would not negate a constitutional injury.

## Issues

1. Whether a municipality and municipal officials may be held liable under 42 U.S.C. § 1983 for alleged unconstitutional policies or customs when the jury has found the individual officer committed no constitutional violation.

## Decision

- The Supreme Court reversed the Ninth Circuit and remanded.
- The jury’s verdict for the officer, given the instructions and absence of any good-faith or immunity charge, constituted a finding of no constitutional injury.
- Because the City and Commission members were sued only as legally responsible for the officer’s actions, they could not be liable in damages without an underlying constitutional violation by the officer.

## Legal Principles

- Municipal liability under 42 U.S.C. § 1983 requires an underlying constitutional violation that caused the plaintiff’s injury.
- When a factfinder determines an individual officer inflicted no constitutional injury, that finding forecloses derivative § 1983 liability against the municipality and related officials based on that officer’s conduct.
- Appellate courts should not speculate that a jury relied on defenses (e.g., good faith or qualified immunity) when the jury was not instructed on such defenses.

## Conclusion

The Court held that a jury finding of no constitutional injury by the officer eliminates any basis for § 1983 damages liability against the city or its police commission members predicated on that officer’s actions, even if departmental regulations might be constitutionally problematic in the abstract.


City of Los Angeles v. Heller, 475 U.S. 796 (1986)