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Law School Case Brief

Rizzo v. Goode - 423 U.S. 362, 96 S. Ct. 598 (1976)


Federal judicial powers may be exercised only on the basis of a constitutional violation.


Two class actions under the Civil Rights Act of 1871, 42 U.S.C.S. § 1983, were filed in the United States District Court for the Eastern District of Pennsylvania against defendants Philadelphia's Mayor, City Managing Director, and supervisory police officials; plaintiffs were seeking equitable relief because of an allegedly pervasive pattern of unconstitutional police mistreatment of minority citizens in particular and of all city residents in general. After parallel trials of the separate actions, the District Court concluded that the evidence showed an unacceptably high number of incidents of police misconduct, for which the defendants should be held responsible because of their failure to act in the face of the statistical "pattern" of misconduct, and entered an order requiring the defendants to submit for the court's approval a program for improving the handling of citizen complaints alleging police misconduct, in accordance with guidelines contained in the court's opinion. A proposed program, negotiated between the parties, was thereafter incorporated into a final judgment by the District Court, and the United States Court of Appeals for the Third Circuit affirmed the pertinent part of the District Court's judgment.


Did the district court exceed its authority when it required defendants to submit a program for improving the handling of citizen complaints alleging police misconduct?




The United States Supreme Court reversed, holding that the District Court had exceeded its authority under the Civil Rights Act of 1871. According to the Court, the District Court had unwarrantedly interfered with the defendants' latitude in the dispatch of internal affairs, and had departed from principles of federalism militating against federal court interference with state agencies and officials, since the evidence showed that only a few individual police officers, not named as parties, had violated the constitutional rights of particular individuals. Moreover, there was no affirmative link between the various incidents of police misconduct and the adoption of any plan or policy by the defendants showing their authorization or approval of the misconduct, and the evidence showed only some 20 incidents of police misconduct in 12 months in the city of three million inhabitants with 7,500 policemen, thus not establishing a "pattern" of misconduct.

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