Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit, No. 91-1657

CourtUnited States Supreme Court
Writing for the CourtREHNQUIST
Citation113 S.Ct. 1160,122 L.Ed.2d 517,507 U.S. 163
Docket NumberNo. 91-1657
Decision Date03 March 1993
PartiesCharlene LEATHERMAN, et al., Petitioners v. TARRANT COUNTY NARCOTICS INTELLIGENCE AND COORDINATION UNIT et al

507 U.S. 163
113 S.Ct. 1160
122 L.Ed.2d 517
Charlene LEATHERMAN, et al., Petitioners

v.

TARRANT COUNTY NARCOTICS INTELLIGENCE AND COORDINATION UNIT et al.

No. 91-1657.
Argued Jan. 12, 1993.
Decided March 3, 1993.
Syllabus *

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.

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, 98 S.Ct. 2018, 56 L.Ed.2d 611, do not enjoy absolute or qualified immunity from § 1983 suits, id., at 701, 98 S.Ct., at 2041; Owen v. City of Independence, 445 U.S. 622, 650, 100 S.Ct. 1398, 1415, 63 L.Ed.2d 673. 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. ____.

954 F.2d 1054 (CA5 1992), reversed and remanded.

REHNQUIST, C.J., delivered the opinion for a unanimous Court.

Richard Gladden, Denton, TX, for petitioners.

Brett A. Ringle, Dallas, TX, for respondents.

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. ----, ----, 111 S.Ct. 1267, ----, 113 L.Ed.2d 335 (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, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978), was the failure of these bodies adequately to train the police officers involved. See Canton v. Harris, 489 U.S. 378, 109 S.Ct. 1197, 103 L.Ed.2d 412 (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. ----, 112 S.Ct. 2989, 120 L.Ed.2d 867 (1992), to resolve a conflict among the Courts of Appeals concerning...

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3746 practice notes
  • Estate of Bryant v. Balt. Police Dep't, Civil Action No. ELH-19-384
    • United States
    • United States District Courts. 4th Circuit. United States District Court (Maryland)
    • February 10, 2020
    ...550 U.S. at 555). That standard applies to § 1983 claims. See Leatherman v. Tarrant Cty. Narcotics Intelligence & Coordination Unit, 507 U.S. 163, 168 (1993) (rejecting heightened pleading standards for § 1983 claims). This standard, the Supreme Court has explained, is "a context-s......
  • C.S.B. Commodities, Inc. v. Urban Trend (Hk) Ltd., Case No. 08 cv 1548.
    • United States
    • United States District Courts. 7th Circuit. United States District Court (Northern District of Illinois)
    • January 7, 2009
    ...under § 1983. Expressio unius est exclusio alterius." Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit, 507 U.S. 163, 168, 113 S.Ct. 1160, 122 L.Ed.2d 517 (1993). Although unfair competition claims are not one of the enumerated 9(b) actions, the Lanham Act prot......
  • Shi Liang Lin v. U.S. Dept. of Justice, Docket No. 02-4611-ag.
    • United States
    • U.S. Court of Appeals — Second Circuit
    • July 16, 2007
    ...534 U.S. 19, 28, 122 S.Ct. 441, 151 L.Ed.2d 339 (2001); Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit, 507 U.S. 163, 168, 113 S.Ct. 1160, 122 L.Ed.2d 517 The language of § 601(a) does nothing to alter the pre-IIRIRA definition of "political opinion" in ......
  • City of Dover v. U.S. Envtl. Prot. Agency, Civil Action No. 12–1994(JDB).
    • United States
    • United States District Courts. United States District Court (Columbia)
    • July 30, 2013
    ...U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974); see also Leatherman v. Tarrant Cnty. Narcotics Intelligence & Coordination Unit, 507 U.S. 163, 164, 113 S.Ct. 1160, 122 L.Ed.2d 517 (1993). Therefore, the factual allegations must be presumed true, and plaintiffs must be given every fa......
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3746 cases
  • C.S.B. Commodities, Inc. v. Urban Trend (Hk) Ltd., Case No. 08 cv 1548.
    • United States
    • United States District Courts. 7th Circuit. United States District Court (Northern District of Illinois)
    • January 7, 2009
    ...liability under § 1983. Expressio unius est exclusio alterius." Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit, 507 U.S. 163, 168, 113 S.Ct. 1160, 122 L.Ed.2d 517 (1993). Although unfair competition claims are not one of the enumerated 9(b) actions, the Lanham Act......
  • City of Dover v. U.S. Envtl. Prot. Agency, Civil Action No. 12–1994(JDB).
    • United States
    • United States District Courts. United States District Court (Columbia)
    • July 30, 2013
    ...416 U.S. 232, 236, 94 S.Ct. 1683, 40 L.Ed.2d 90 (1974); see also Leatherman v. Tarrant Cnty. Narcotics Intelligence & Coordination Unit, 507 U.S. 163, 164, 113 S.Ct. 1160, 122 L.Ed.2d 517 (1993). Therefore, the factual allegations must be presumed true, and plaintiffs must be given every fa......
  • Ashiegbu v. Purviance, No. C-2-98-28.
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    • United States District Courts. 6th Circuit. United States District Courts. 6th Circuit. Southern District of Ohio
    • November 17, 1998
    ...subject to the liberal federal rules of "notice pleading." See Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit, 507 U.S. 163, 168, 113 S.Ct. 1160, 122 L.Ed.2d 517 (1993). To establish liability under § 1983 against state (or municipal) officials acting in their ind......
  • Hadad v. Croucher, No. 1:87 CV 1211.
    • United States
    • U.S. District Court — Northern District of Ohio
    • January 28, 1997
    ...The Village itself, of course, cannot utilize this defense. Leatherman v. Tarrant Cty. Narcotics Intelligence and Coordination Unit, 507 U.S. 163, 164-66, 113 S.Ct. 1160, 1161-62, 122 L.Ed.2d 517, 523 (1993); Owen v. City of Independence, Page 1242 U.S. 622, 650, 100 S.Ct. 1398, 1415, 63 L.......
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6 books & journal articles
  • Reflections on "Moving Toward Integration" and Modern Exclusionary-Zoning Cases Under the Fair Housing Act.
    • United States
    • Case Western Reserve Law Review Vol. 70 Nbr. 3, March 2020
    • March 22, 2020
    ...Federal Rules, and not by judicial interpretation.'") (quoting Leatherman v. Tarrant Cty. Narcotics Intelligence & Coordination Unit, 507 U.S. 163, 168 (1993)). The federal rules may be amended only pursuant to the Rules Enabling Act. See 28 U.S.C. [section][section] 2071-74 (117.) Cf. ......
  • DETERMINATION OF THE U.S. PLEADING FROM THE CIVIL LAW PERSPECTIVE.
    • United States
    • Washington University Global Studies Law Review Vol. 21 Nbr. 2, March 2022
    • March 22, 2022
    ...note 39, at 992. (49) See Conley v. Gibson, 355 U.S. 41 (1957); Leatherman v. Tarrant Cnty. Narcotics Intel. & Coordination Unit, 507 U.S. 163 (1993); Swierkiewicz, supra note 44, at (50) See Miller, From Conley, supra note 1, at 12; Fairman, supra note 45, at 996. (51) See Swierkiewicz......
  • THE COLLAPSE OF THE FEDERAL RULES SYSTEM.
    • United States
    • University of Pennsylvania Law Review Vol. 169 Nbr. 8, August 2021
    • August 1, 2021
    ...toward "noncontroversial, largely meaningless efforts"). (105) E.g., Leatherman v. Tarrant Cnty. Narcotics Intel. & Coordination Unit, 507 U.S. 163, 168 (1993) (rejecting the lower court's effort to craft a heightened pleading requirement for civil rights litigation against local govern......
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    • May 1, 2018
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