Board of the County Commissioners of Bryan County v. Brown
- Decided
- April 28, 1997
- Docket
- 95-1100
- Status
- Published
- Jurisdiction
- Federal
Cited 7,185 timesNo negative treatment found in this library
What later courts said
- holding that a municipality may not be held liable under Section 1983 on a theory of respondeat superior — Carbajal v. County of Nassau (2003)
- holding that only "deliberate" action by a municipality can meet the "moving force" requirement — (untitled) (1999)
- holding that a plaintiff “must demonstrate a direct causal link between the municipal action and the deprivation of federal rights” — Johnson v. Andalusia Police Department (2009)
Each line is a later court’s own words about this case, not a summary. Read the opinion before relying on it.
How the opinion begins
Justice O’Connor delivered the opinion of the Court.
Respondent Jill Brown brought a claim for damages against petitioner Bryan County under Rev. Stat. § 1979, 42 U. S. C. § 1983. She alleged that a county police officer used [*400] excessive force in arresting her, and that the county itself was liable for her injuries based on its sheriff’s hiring and training decisions. She prevailed on her claims against the county following a jury trial, and the Court of Appeals for the Fifth Circuit affirmed the judgment against the county on the basis of the hiring claim alone. 67. F. 3d 1174 (1995). We granted certiorari. We conclude that the Court of Appeals’ decision cannot be squared with our recognition that, in enacting § 1983, Congress did not intend to impose liability on a municipality unless deliberate action attributable to the municipality itself is the “moving force” behind the plaintiff’s deprivation of federal rights. Monell v. New York City Dept. of Social Servs., 436 U. S. 658, 694 (1978).
I
Statutes cited
Cite this
Board of the County Commissioners of Bryan County v. Brown, 520 U.S. 397 (1997)Read the full opinion
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