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City of St. Louis v. Praprotnik

United States Supreme Court
485 U.S. 112 (1988)


Facts

James H. Praprotnik (plaintiff) was an architect who began working for the City of St. Louis in 1968. By 1980, Praprotnik held a management position at the city’s Community Development Agency (CDA). In April 1980, Praprotnik was suspended for 15 days for accepting outside work without prior approval, in violation of CDA policy. Praprotnik appealed to the city’s Civil Service Commission (CSC), which reversed the suspension and awarded back pay. In 1982, Praprotnik was transferred to another position without his approval, and his appeal to the CSC was denied, because he had not been demoted or had his pay cut. In 1983, Praprotnik was laid off due to lack of city funds. Praprotnik filed a § 1983 suit in federal district court alleging that the transfer and layoff were unconstitutional, and named as defendants the city and three individual city officials (defendants), including Frank Hamsher, the supervisor at CDA responsible for the transfer. The jury found in favor of the officials, but found the city liable for retaliatory actions in violation of Praprotnik’s First Amendment rights. The United States Court of Appeals for the Eighth Circuit affirmed, finding that the jury had implicitly determined that the layoff was the result of an unconstitutional city policy. The court of appeals reasoned that the city was liable for the decisions of policymakers whose employment decisions are final. The court of appeals also found that the CSC’s scope of review did not change the fact that the policymakers were the true final authority. The United States Supreme Court granted certiorari.

Rule of Law

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Issue

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Holding and Reasoning (O’Connor, J.)

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Concurrence (Brennan, J.)

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Dissent (Stevens, J.)

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