Aldinger v. Howard
United States Supreme Court
427 U.S. 1 (1976)
Howard (defendant) was the treasurer of Spokane County, Washington. Howard hired Aldinger (plaintiff) as a clerk, dismissible at Howard's will. Two months later and despite an excellent work evaluation, Howard fired Aldinger for living with her boyfriend. Aldinger requested but was denied a pre-dismissal hearing. Citing a civil rights statute, 42 U.S.C. § 1983, Aldinger sued Howard, county officials, and the county (defendants) in the United States District Court for the Eastern District of Washington. Aldinger alleged violations of several of her constitutional rights. Additionally, Aldinger asserted state law claims, and argued the federal court had pendent jurisdiction over those claims. The district court dismissed Aldinger's complaint against the county, on the grounds that § 1983 allowed suits against individuals but not municipalities. Aldinger appealed the dismissal to the United States Court of Appeals for the Ninth Circuit. The appellate court agreed the county could not be sued under § 1983 and also rejected Aldinger's argument about pendent jurisdiction. Aldinger appealed to the United States Supreme Court, which confined its consideration to the issue of pendent jurisdiction.
Rule of Law
Holding and Reasoning (Rehnquist, J.)
Dissent (Brennan, J.)
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