Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit

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 [*165] 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 to adequately train the police officers involved. See Canton v. Harris, 489 U. S. 378 (1989).