Los Angeles County v. Humphries (09-350)
argument 09-350Los Angeles County v. Humphries
Supreme Court of the United States
55 min
4 speakers
8 chapters
transcribed 6 days ago
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What is the Monell doctrine and how does it limit municipal liability under §1983?
We'll hear argument next in case zero nine three fifty, Los Angeles County versus Humphreys. Mr Coates?
Mr Chief Justice, and may it please the Court. In Manel versus Department of Social Services, this court held there could be no liability against a local public entity under Section 1983. unless the plaintiff proved causation. namely that the injury that was inflicted was inflicted as a result of a custom, policy or practice of that local public entity. The Ninth Circuit, however, in this case, has imposed ex post facto declaratory relief on the County of Los Angeles as well as a substantial fee award. While acknowledging that it has not in fact determined whether the injury suffered by the plaintiffs and subject to the declaratory relief was the result of a policy, custom or practice fairly attributable to the county of Los Angeles.
It did so because in the Ninth Circuit has developed a digression from the courts jurisprudence in Minnel, namely, in the Ninth Circuit claims for prospective relief, both injunctive and declaratory relief, are not subject to the Minnell requirements. We submit that this is flatly y inconsistent with Minnel and erodes the important principles of federalism
declaratory judgment is not uh affect the fisk of the Yes, essentially. It does it does though, if if if you have attorney's fees. What what what what was the total uh attorney's fee award in this case?
Um As to the the county, it's fifty eight thousand dollars, but the overall award is far above that and that's just for appellate attorneys fees. We're not even talking trial fees at this time.
What's far above? Like what?
Um six hundred and some odd thousand dollars.
But there was no objection on the part of the state. The state was to pay the lion's share of the fees, I think ninety percent, right?
Correct. And
the state is not contesting.
The state has not contested that, correct.
Does does the state make that payment under an ex parte young theory?
Yes, yes. It's a suit against the state under ex parte young uh theory since they maintain the statute.
If you sue the municipality, uh they denied marriage licenses of do you have to sue under nineteen eighty three or you can just sue alleging a federal cause of action under Because of a denial of a constitutional right.
Uh would have to be the courts recognized against local municipalities liability under section nineteen eighty-three.
The only way to sue a municipality for constitutional violation is under nineteen eighty three?
In a direct civil cause of action. I believe that is correct, Your Honor.
Well, you could get the individual uh officer who's uh denying the marriage license or whatever the offensive uh act is. You could sue that person under nineteen eighty three and get uh And get injunctive relief, I suppose.
That is correct. You could also sue the individual.
But could you sue outside of nineteen eighty three?
the individual for a federal constitutional remedy?
Uh no, I believe that y would still have to have an operative statute to get it into federal court. For declaratory relief requires some of the things that we have to do. And that
has to be a statute, it has to be nineteen eighty three?
I believe for a constitutional claim of this type it would be Section nineteen eighty three. You might find an employment case where you might have Title Seven concerns. It depends on the the the right that you're talking, it's at issue.
Ignore the injunction. Can you go to the state and force the state to in that circumstance to to get someone to issue the licence on your behalf?
Uh i if it's we're talking about the state are you referring to the municipality? Um you would not unless you show that there was a policy, custom or practice. So what you're
saying is that a state Agent. or s or a municipality can continue to ignore a constitutional violation. Until what? You're denied the license five times? Well no. How many times do you have to show that you're not getting a license you are entitled to?
Well, say for example, if one one brought to the attention of a policymaking official that this is what was going on,
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Chapters
8 chapters
1
What is the Monell doctrine and how does it limit municipal liability under §1983?
0:03–6:37
2
How do the parties calculate and argue about the attorney‑fees award in this case?
6:37–13:15
3
When does an ex parte Young claim apply to state officials versus local municipalities?
13:15–20:40
4
What constitutes a “policy, custom, or practice” sufficient for prospective injunctive relief?
20:40–27:46
5
How does the Ninth Circuit’s treatment of ongoing constitutional violations differ from Monell’s causation requirement?
27:46–33:52
6
Why is the distinction between state and county responsibility critical for federalism?
33:52–41:05
7
What are the arguments for and against imposing declaratory and injunctive relief without a proven policy?
41:05–48:19
8
How might the Court’s decision affect future §1983 claims and municipal procedural obligations?
48:19–55:33