## Facts

- Ronda Morrison was murdered in Monroe County, Alabama; Walter McMillian was indicted, convicted of capital murder, and sentenced to death.
- A key witness, Ralph Myers, testified against McMillian after pleading to a lesser offense.
- The Alabama Court of Criminal Appeals reversed McMillian’s conviction on Brady grounds based on suppressed exculpatory and impeaching evidence, including statements by Myers inconsistent with his trial testimony.
- McMillian spent about six years on death row before release.
- McMillian filed a 42 U.S.C. § 1983 suit alleging that Sheriff Tom Tate and other officials coerced false statements and suppressed exculpatory evidence; Tate and a district attorney investigator were sued in their official capacities.
- McMillian sought to hold Monroe County liable on the theory that the sheriff’s conduct constituted county policy in law enforcement.

## Issues

1. For § 1983 municipal liability under Monell, does an Alabama sheriff act as a final policymaker for the county or for the State when performing law-enforcement duties?

## Decision

- The Supreme Court affirmed the dismissal of the § 1983 claims against Monroe County.
- The Court held that, in the law-enforcement functions at issue, an Alabama sheriff represents the State of Alabama, not the county.
- Because the sheriff was not a county policymaker in that domain, his alleged misconduct could not be treated as Monroe County policy for Monell purposes.

## Legal Principles

- A local government is liable under § 1983 only for actions taken pursuant to its own policy or custom; respondeat superior liability is unavailable.
- Identifying a “final policymaker” for Monell purposes turns on state law and the specific governmental function involved.
- An official’s status as a state or local policymaker may vary by function and issue; courts must conduct a function-specific analysis grounded in state constitutional, statutory, and decisional law.
- When state law assigns relevant law-enforcement authority to a state official rather than the county, the county is not subject to Monell liability for that official’s conduct in that domain.

## Conclusion

The Court concluded that Alabama sheriffs act on behalf of the State, not the county, when carrying out law-enforcement duties; therefore, alleged investigative and prosecutorial misconduct by the sheriff did not constitute county policy and could not support § 1983 liability against Monroe County.


McMillian v. Monroe Cnty., 520 U.S. 781 (1997)