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Leatherman v. Tarrant Cty. Nicu, 507 U.S. 163 (1993)
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General SummaryThis case is from a collection containing the full text of over 16,000 Supreme Court cases from 1793 to the present. The body of Supreme Court decisions are, effectively, the final interpretation of the Constitution. Only an amendment to the Constitution can permanently overturn an interpretation and this has happened only four times in American history.
Leatherman v. Tarrant Cty. Nicu, 507 U.S. 163 (1993)
Leatherman v. Tarrant County Narcotics Intelligence and Coordination Unit No. 91-1657 Argued Jan. 12, 1993 Decided March 3, 1993 507 U.S. 163
CERTIORARI TO THE UNITED STATES COURT OF APPEALS
FOR THE FIFTH CIRCUIT
Syllabus
Petitioner homeowners filed suit under 42 U.S.C. § 1983 against respondents -- local officials acting in their official capacity, a county, and two municipal corporations -- alleging that the conduct of local police officers in searching their homes for narcotics violated the Fourth Amendment, and asserting that the basis for municipal liability was the failure adequately to train the police officers involved. The Federal District Court dismissed the complaints because they failed to meet the "heightened pleading standard" adopted by the Court of Appeals, which requires that complaints against municipal corporations in § 1983 cases state with factual detail and particularity the basis for the claim. The Court of Appeals affirmed.
Held: A federal court may not apply a "heightened pleading standard" -- more stringent than the usual pleading requirements of Federal Rule of Civil Procedure 8(a) -- in civil rights cases alleging municipal liability under § 1983. First, the heightened standard cannot be justified on the ground that a more relaxed pleading standard would eviscerate municipalities’ immunity from suit by subjecting them to expensive and time-consuming discovery in every § 1983 case. Municipalities, although free from respondeat superior liability under § 1983, see Monell v. New York City Dept. of Social Services, 436 U.S. 658, do not enjoy absolute or qualified immunity from § 1983 suits, id. at 701; Owen v. City of Independence, 445 U.S. 622, 650. Second, it is not possible to square the heightened standard applied in this case with the liberal system of "notice pleading" set up by the Federal Rules. Rule 8(a)(2) requires that a complaint include only "a short and plain statement of the claim showing that the pleader is entitled to relief." And while Rule 9(b) requires greater particularity in pleading certain actions, it does not include among the enumerated actions any reference to complaints alleging municipal liability under § 1983. Pp. 165-169.
954 F.2d 1054 (CA5 1992), reversed and remanded.
REHNQUIST, C.J., delivered the opinion for a unanimous Court.
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Chicago: U.S. Supreme Court, "Syllabus," Leatherman v. Tarrant Cty. Nicu, 507 U.S. 163 (1993) in 507 U.S. 163 507 U.S. 164. Original Sources, accessed November 22, 2024, http://originalsources.com/Document.aspx?DocID=S17T1T9YF8BVJFT.
MLA: U.S. Supreme Court. "Syllabus." Leatherman v. Tarrant Cty. Nicu, 507 U.S. 163 (1993), in 507 U.S. 163, page 507 U.S. 164. Original Sources. 22 Nov. 2024. http://originalsources.com/Document.aspx?DocID=S17T1T9YF8BVJFT.
Harvard: U.S. Supreme Court, 'Syllabus' in Leatherman v. Tarrant Cty. Nicu, 507 U.S. 163 (1993). cited in 1993, 507 U.S. 163, pp.507 U.S. 164. Original Sources, retrieved 22 November 2024, from http://originalsources.com/Document.aspx?DocID=S17T1T9YF8BVJFT.
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