## Facts

- California maintained the Child Abuse Central Index (CACI), a statewide database of certain child-abuse reports accessible to public agencies for at least 10 years.
- The governing law provided no procedure for an individual to contest inclusion in CACI, and no state or county procedures had been created.
- Craig and Wendy Humphries were accused of child abuse in Los Angeles County and were listed in CACI as “substantiated.”
- The allegations were later determined to be unfounded, but the Humphries were told there was no mechanism to remove their names or challenge the listing.
- The Humphries sued under 42 U.S.C. § 1983 against state and local officials, including Los Angeles County, seeking damages and prospective relief (injunction and declaratory judgment) for denial of procedural due process.
- The district court granted summary judgment for defendants.
- The Ninth Circuit reversed in relevant part, ordered declaratory relief, and treated the Humphries as prevailing against the County for fee purposes without requiring proof that a county “policy or custom” caused the violation.

## Issues

1. Whether Monell’s requirement that a municipality is liable under § 1983 only for injuries caused by its own “policy or custom” applies when the plaintiff seeks prospective relief (injunctive or declaratory), not just damages.
2. Whether the Ninth Circuit erred by imposing prospective relief and related fee liability on a county without requiring proof of a county policy or custom.

## Decision

- The Supreme Court reversed the Ninth Circuit and remanded.
- Monell’s “policy or custom” requirement applies in § 1983 cases regardless of whether the relief sought is monetary or prospective.
- Because the Ninth Circuit imposed county liability for declaratory relief without applying Monell, its judgment (including the basis for fees against the County) could not stand.
- The Court left to the lower courts on remand whether the alleged constitutional violation was attributable to a county policy or custom rather than solely state law.

## Legal Principles

- A municipality is a “person” under § 1983, but it is not liable on a respondeat superior theory for constitutional violations by its employees.
- Municipal liability under § 1983 requires that the constitutional injury be caused by execution of the municipality’s own policy or custom.
- The Monell policy-or-custom requirement is an element of municipal liability for all remedies authorized by § 1983, including damages, injunctions, and declaratory judgments.
- Section 1983’s remedial language (“action at law, suit in equity, or other proper proceeding”) does not create different standards for municipal liability based on the remedy requested.

## Conclusion

The Court held that plaintiffs seeking any form of relief against a municipality under § 1983 must satisfy Monell by showing the alleged constitutional violation was caused by the municipality’s own policy or custom, and it remanded for application of that standard to Los Angeles County.


Los Angeles County v. Humphries, 562 U.S. 29 (2010)