Bd. of the Cnty. Comm’rs v. Brown
Supreme Court of the United States
November 5, 1996, Argued ; April 28, 1997, Decided
[*399] [**1386] [***636] JUSTICE O'CONNOR delivered the opinion of the Court.
Respondent Jill Brown brought a claim for damages against petitioner Bryan [****7] County under Rev. Stat. § 1979, 42 U.S.C. § 1983. She alleged that a county police officer used [*400] excessive force in arresting her, and that the county itself was liable for her injuries based on its sheriff's hiring and training decisions. She prevailed on her claims against the county following a jury trial, and the Court of Appeals for the Fifth Circuit affirmed the judgment against the county on the basis of the hiring claim alone. 67 F.3d 1174 (1995). We granted certiorari. We conclude that the Court of Appeals' decision cannot be squared with our recognition that, ] in enacting § 1983, Congress did not intend to impose liability on a municipality unless deliberate action attributable to the municipality itself is the "moving force" behind the plaintiff's deprivation of federal rights. Monell v. New York City Dept. of Social Servs., 436 U.S. 658, 694, 56 L. Ed. 2d 611, 98 S. Ct. 2018 (1978).
In the early morning hours of May 12, 1991, respondent Jill Brown and her husband were driving from Grayson County, Texas, to their home in Bryan County, Oklahoma. After crossing into Oklahoma, they approached a police checkpoint. Mr. Brown, who was driving, decided to avoid the checkpoint and return to [****8] Texas. After seeing the Browns' truck turn away from the checkpoint, Bryan County Deputy Sheriff Robert Morrison and Reserve Deputy Stacy Burns pursued the vehicle. Although the parties' versions of events differ, at trial both deputies claimed that their patrol car reached speeds in excess of 100 miles per hour. Mr. Brown testified that he was unaware of the deputies' attempts to overtake him. The chase finally ended four miles south of the police checkpoint.
After he got out of the squad car, Deputy Sheriff Morrison pointed his gun toward the Browns' vehicle and ordered the Browns to raise their hands. Reserve Deputy Burns, who was unarmed, rounded the corner of the vehicle on the passenger's side. Burns twice ordered respondent Jill Brown from the vehicle. When she did not exit, he used an "arm bar" technique, grabbing respondent's arm at the wrist and elbow, [*401] pulling her from the [**1387] vehicle, and spinning her to the ground. Respondent's knees were severely injured, and she later underwent corrective surgery. Ultimately, she may need knee replacements.Read The Full CaseNot a Lexis Advance subscriber? Try it out for free.
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520 U.S. 397 *; 117 S. Ct. 1382 **; 137 L. Ed. 2d 626 ***; 1997 U.S. LEXIS 2793 ****; 65 U.S.L.W. 4286; 97 Cal. Daily Op. Service 3033; 12 I.E.R. Cas. (BNA) 1217; 97 Daily Journal DAR 5311; 10 Fla. L. Weekly Fed. S 405
BOARD OF THE COUNTY COMMISSIONERS OF BRYAN COUNTY, OKLAHOMA, PETITIONER v. JILL BROWN ET AL.
Prior History: [****1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT.
Disposition: 67 F.3d 1174, vacated and remanded.
municipality, Sheriff, policymaker, hiring, municipal liability, deliberate indifference, deliberately, indifferent, training, plainly, screening, arrest, hiring decision, employees, fault, deprivation, constitutional violation, charges, driving, culpability, federal right, causation, cases, skepticism, vicarious, violates, assault, custom, notice, rights
Civil Rights Law, Section 1983 Actions, Scope, Government Actions, Governments, Local Governments, Claims By & Against, Protection of Rights, Scope, Criminal Law & Procedure, Criminal Offenses, Vehicular Crimes, General Overview, Employees & Officials, Obstruction of Administration of Justice, Resisting Arrest, Torts, Vicarious Liability, Employers, Business & Corporate Compliance, Unfair Labor Practices, Employer Violations, Interference With Protected Activities, Elements, Causal Relationship, Public Entity Liability, Liability, Legislation, Statutory Remedies & Rights, Civil Procedure, Jury Trials, Jury Instructions