City of Los Angeles et al. v. Heller
475 U.S. 796 (1986)
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Rule of Law:
A municipal entity cannot be held liable under 42 U.S.C. § 1983 for a constitutional violation based on its policies or customs if a jury has concluded that the municipal employee did not inflict any constitutional injury on the plaintiff.
Facts:
- Los Angeles police officers stopped Ronald Heller on suspicion of driving while intoxicated.
- The officers administered a series of field sobriety tests to Heller.
- Unsatisfied with the test results, the officers decided to arrest Heller and transport him to the police station for a breath test.
- When informed that he was under arrest, Heller became belligerent.
- An altercation ensued as Officer Bushey attempted to handcuff Heller.
- In the course of the struggle, Heller fell through a plate glass window.
Procedural Posture:
- Ronald Heller sued the City of Los Angeles, members of its Police Commission, and two police officers in the U.S. District Court for the Central District of California under 42 U.S.C. § 1983.
- The District Court granted summary judgment in favor of one of the two named officers.
- The court bifurcated the trial, proceeding first with the claim against the remaining individual officer, Officer Bushey.
- A jury returned a general verdict in favor of Officer Bushey.
- Based on the jury's verdict, the District Court then dismissed Heller's action against the City of Los Angeles and the Police Commission.
- Heller (appellant) appealed the dismissal to the U.S. Court of Appeals for the Ninth Circuit.
- The Court of Appeals reversed the District Court's dismissal, holding that the claim against the City and Commission (appellees) could proceed.
- The City of Los Angeles and the Police Commission (petitioners) petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a jury verdict exonerating a police officer of inflicting a constitutional injury preclude a finding of liability against the officer's municipal employer under 42 U.S.C. § 1983 for a claim based on the same incident?
Opinions:
Majority - Per Curiam
Yes. A municipal entity cannot be held liable under § 1983 if its employee is found to have inflicted no constitutional harm. The court reasoned that juries are presumed to follow their instructions, and the jury in this case was instructed that it must find for Heller if he was arrested without probable cause or if Officer Bushey used unreasonable force. By returning a verdict for the officer, the jury necessarily found that Heller suffered no constitutional deprivation on either ground. Because Heller suffered no constitutional injury at the hands of the individual officer, it is inconceivable that the City of Los Angeles or its Police Commission could be held liable. The fact that departmental regulations might have authorized the use of excessive force is irrelevant if no constitutionally excessive force was actually used in this instance.
Dissenting - Justice Marshall
Justice Marshall dissented from the court's summary disposition. He argued that the case should not have been decided without affording the parties the opportunity to submit full briefs on the merits and present oral arguments, criticizing the procedural haste of the decision.
Dissenting - Justice Stevens
No. A verdict for the officer should not automatically foreclose liability for the municipality. The majority's decision rests on a flawed assumption that the jury's verdict for Officer Bushey was not reconcilable with a finding of liability against the city. The jury, instructed to consider 'all the surrounding circumstances,' could have concluded that the officer's conduct was reasonable precisely because he was following established departmental policy. Such a finding would not preclude a separate determination that the policy itself was unconstitutional. Furthermore, even if the verdicts were inconsistent, the proper remedy was not to dismiss the case against the city but to employ other judicial tools, such as resubmitting the issue to the jury or ordering a new trial.
Analysis:
This decision establishes a significant prerequisite for municipal liability claims under 42 U.S.C. § 1983. It clarifies that a plaintiff cannot succeed on a claim that a municipal policy is unconstitutional in the abstract; they must first prove that an individual officer, acting pursuant to that policy, inflicted an actual constitutional injury. The ruling effectively makes municipal liability derivative of the individual officer's constitutional tort in cases like this. Consequently, it provides a powerful defense for municipalities and encourages the litigation strategy of bifurcating trials to first adjudicate the liability of the individual officer.
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