507 U.S. 163 (1993), 91-1657, Leatherman v. Tarrant County Narcotics
|Docket Nº:||No. 91-1657|
|Citation:||507 U.S. 163, 113 S.Ct. 1160, 122 L.Ed.2d 517, 61 U.S.L.W. 4205|
|Party Name:||Leatherman v. Tarrant County Narcotics|
|Case Date:||March 03, 1993|
|Court:||United States Supreme Court|
Intelligence and Coordination Unit
Argued Jan. 12, 1993
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE FIFTH CIRCUIT
Petitioner homeowners filed suit under 42 U.S.C. § 1983 against respondents -- local officials acting in their official capacity, a county, and two municipal corporations -- alleging that the conduct of local police officers in searching their homes for narcotics violated the Fourth Amendment, and asserting that the basis for municipal liability was the failure adequately to train the police officers involved. The Federal District Court dismissed the complaints because they failed to meet the "heightened pleading standard" adopted by the Court of Appeals, which requires that complaints against municipal corporations in § 1983 cases state with factual detail and particularity the basis for the claim. The Court of Appeals affirmed.
[113 S.Ct. 1161] Held: A federal court may not apply a "heightened pleading standard" -- more stringent than the usual pleading requirements of Federal Rule of Civil Procedure 8(a) -- in civil rights cases alleging municipal liability under § 1983. First, the heightened standard cannot be justified on the ground that a more relaxed pleading standard would eviscerate municipalities' immunity from suit by subjecting them to expensive and time-consuming discovery in every § 1983 case. Municipalities, although free from respondeat superior liability under § 1983, see Monell v. New York City Dept. of Social Services, 436 U.S. 658, do not enjoy absolute or qualified immunity from § 1983 suits, id. at 701; Owen v. City of Independence, 445 U.S. 622, 650. Second, it is not possible to square the heightened standard applied in this case with the liberal system of "notice pleading" set up by the Federal Rules. Rule 8(a)(2) requires that a complaint include only "a short and plain statement of the claim showing that the pleader is entitled to relief." And while Rule 9(b) requires greater particularity in pleading certain actions, it does not include among the enumerated actions any reference to complaints alleging municipal liability under § 1983. Pp. 165-169.
954 F.2d 1054 (CA5 1992), reversed and remanded.
REHNQUIST, C.J., delivered the opinion for a unanimous Court.
REHNQUIST, J., lead opinion
CHIEF JUSTICE REHNQUIST delivered the opinion of the Court.
We granted certiorari to decide whether a federal court may apply a "heightened pleading standard" -- more stringent than the usual pleading requirements of Rule 8(a) of the Federal Rules of Civil Procedure -- in civil rights cases alleging municipal liability under Rev.Stat. § 1979, 42 U.S.C. § 1983. We hold it may not.
We review here a decision granting a motion to dismiss, and therefore must accept as true all the factual allegations in the complaint. See United States v. Gaubert, 499 U.S. 315, 327 (1991). This action arose out of two separate incidents involving the execution of search warrants by local law
enforcement officers. Each involved the forcible entry into a home based on the detection of odors associated with the manufacture of narcotics. One homeowner claimed that he was assaulted by the officers after they had entered; another claimed that the police had entered her home in her absence and killed her two dogs. Plaintiffs sued several local officials in their official capacity and the county and two municipal corporations that employed the police officers involved in the incidents, asserting that the police conduct had violated the Fourth Amendment to the United States Constitution. The stated basis for municipal liability under Monell v. New York City Dept. of Social Services, 436 U.S. 658 (1978), was the failure of these bodies adequately to train the police officers involved. See Canton v. Harris, 489 U.S. 378 (1989).
The United States District Court for the Northern District of Texas ordered the complaints dismissed because they failed to meet the "heightened pleading standard" required by the decisional law of the Court of Appeals for the Fifth Circuit. 755 F.Supp. 726 (1991). The Fifth Circuit, in turn, affirmed the judgment of dismissal, 954 F.2d 1054 (1992), and we granted certiorari, 505 U.S. 1203 (1992), to resolve a conflict among the Courts of Appeals concerning the applicability of a heightened pleading standard to § 1983 actions alleging municipal liability. Compare, e.g., Karim-Panahi v. Los Angeles Police Dept., 839 F.2d 621, 624 (CA9 1988) [113 S.Ct. 1162] ("a claim of municipal liability under section 1983 is sufficient to withstand a motion to dismiss even if the...
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