Los Angeles County v. Humphries
United States Supreme Court
562 U.S. 29 (2010)

- Written by Katrina Sumner, JD
Facts
Two parents, Craig and Wendy Humphries (plaintiffs), were falsely accused of child abuse and arrested. The day after their arrest, a detective of the Los Angeles County Sheriff’s Department (defendant) listed the Humphries’ names in California’s Child Abuse Central Index (the index), labeling their case a substantiated report of child abuse. However, upon investigation, the parents were later proven to be innocent. When the Humphries sought to have their names removed from the index, the sheriff’s department refused to remove their names voluntarily, and the Humphries were informed that there was no procedure for removing names once added to the index. The Humphries then sued California’s attorney general, the sheriff’s department, two detectives, and Los Angeles County (defendants), alleging a violation of their constitutional due-process rights under 42 U.S.C. § 1983. The Ninth Circuit ruled that under the Fourteenth Amendment, people listed in the index should be provided with notice and a hearing. The Ninth Circuit also ruled that under the Supreme Court’s holding in Monell v. New York City Department of Social Services, the Humphries were due declaratory relief and damages if proven, but not prospective relief. The Ninth Circuit held that the Humphries were entitled to attorney’s fees and ordered the defendants to pay the Humphries’ attorney’s fees in the amount of $600,000. Los Angeles County denied liability for a state policy or that it should be held responsible for $60,000 of the Humphries’ attorney’s fees as ordered. Los Angeles County asked the Supreme Court to review the Ninth Circuit’s ruling that Monell did not apply to prospective relief. In Monell, the Supreme Court held that a plaintiff could recover for an injury caused by a government’s policy or custom. However, that case involved money damages. The question before the Supreme Court now was whether the holding also applied to prospective relief such as declaratory judgments and injunctions.
Rule of Law
Issue
Holding and Reasoning (Breyer, J.)
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