## Facts

- Philadelphia residents and organizations brought class actions under 42 U.S.C. § 1983 alleging a pattern of unconstitutional police mistreatment, particularly of Black residents.
- The suits relied on evidence of numerous incidents of alleged excessive force and related misconduct by individual officers.
- After an extensive evidentiary record, the district court found a pattern of unconstitutional mistreatment but also found no policy by the named city and police supervisors to violate constitutional rights.
- The district court concluded only a small percentage of officers committed violations, but the violations were not isolated and the complaint process discouraged reporting and minimized consequences.
- As equitable relief, the district court ordered the supervisory defendants to submit, for court approval, a comprehensive program to revise and administer civilian-complaint and disciplinary procedures under detailed judicial guidelines.
- The court of appeals affirmed the injunction.

## Issues

1. Whether plaintiffs seeking institutional injunctive relief showed a “real and immediate” threat of future injury traceable to the named supervisory officials sufficient to satisfy Article III.
2. Whether § 1983 and federal equitable principles permit a federal court to impose broad, forward-looking structural relief on local executive supervisors absent proof they adopted an unconstitutional policy or affirmatively participated in the violations.

## Decision

- The Supreme Court reversed and vacated the injunction.
- The Court held the required Article III case or controversy was lacking because the feared future injury depended on what a small, unidentified minority of officers might do, not on threatened conduct by the named supervisors.
- The Court held the injunction exceeded permissible § 1983 and equitable remedial authority because the record did not show the named officials played an affirmative role in the constitutional deprivations.
- The Court emphasized federalism limits on federal judicial control over internal administration of local police departments through ongoing supervisory decrees.

## Legal Principles

- Injunctive relief requires a plaintiff to show a real and immediate threat of future injury, not a generalized fear based on past misconduct by others.
- § 1983 does not impose supervisory responsibility solely based on position; there must be an affirmative connection between the supervisor’s acts or policies and the constitutional violation.
- Federal equitable relief must be tied to a proven, attributable constitutional violation and should not function as continuing federal supervision of local executive operations.
- Structural, prophylactic injunctions restructuring state or local agency procedures are disfavored where the named officials are not shown to have directed, approved, or instituted unconstitutional practices.

## Conclusion

The Court vacated a broad injunction restructuring Philadelphia’s police complaint system because plaintiffs did not show a justiciable, imminent injury traceable to the named supervisors and because § 1983 and equitable authority did not support imposing institutional reform on officials not found to have affirmatively caused the constitutional violations.


Rizzo v. Goode, 423 U.S. 362 (1976)