## Facts

- Melvin Carter alleged that in 1968 a Metropolitan Police Department officer arrested him without probable cause and beat him with brass knuckles while other officers held him.
- Carter sued the District of Columbia, the officer, and senior police officials, alleging negligent failure to train and supervise regarding lawful arrests and permissible force.
- Carter sought damages under common-law tort theories and under 42 U.S.C. § 1983 for deprivation of constitutional rights under color of law.

## Issues

1. Whether the District of Columbia is a “State or Territory” within the meaning of 42 U.S.C. § 1983.
2. Whether actions taken under color of District of Columbia law can support § 1983 liability against the District or its officials.

## Decision

- The Supreme Court unanimously held that the District of Columbia is not a “State or Territory” for purposes of § 1983.
- The Court reversed the lower court’s judgment to the extent it allowed Carter’s § 1983 claims to proceed.
- The Court’s disposition did not disturb the separate non-§ 1983 theories the court of appeals had addressed.

## Legal Principles

- Section 1983’s reference to action under color of law of a “State or Territory” does not include the District of Columbia.
- Statutory meaning is informed by the text, contemporaneous usage, and the historical setting of enactment; omission of the District where Congress elsewhere named it expressly supports exclusion.
- Reconstruction-era civil-rights legislation underlying § 1983 was directed primarily at abuses by state officials and state failures to protect federal rights, supporting a reading limited to states and territories.

## Conclusion

The Court limited § 1983’s reach by holding that conduct undertaken under color of District of Columbia law is not action under color of law of a “State or Territory,” requiring plaintiffs to rely on other available legal theories rather than § 1983 for such claims.


District of Columbia v. Carter, 409 U.S. 418 (1973)