In 42 U.S.C. section 1983, Congress created a statutory cause of action against every person who, acting under the color of state law, violates another’s federal rights. In a 1961 decision, Monroe versus Pape, the United States Supreme Court stated that municipal corporations didn’t constitute persons under the statute and therefore weren’t subject to liability. Seventeen years later, in Monell versus Department of Social Services, the validity of Monroe’s statement came into question as the Supreme Court reexamined the scope of the term person under section 1983.
Monell and other female employees of New York City’s Department of Social Services and Board of Education filed a section 1983 action against the department, the board, the city of New York, and associated local-government officials in their official capacities. The employees alleged that the department and board had unconstitutional policies forcing pregnant women into unpaid leaves of absence before medically necessary. The employees sought back pay and injunctive relief. After the complaint was filed, the city changed its maternity-leave policy to prevent forced leave unless medically necessary. The city, its entities, and associated local-government officials argued that the change rendered injunctive relief moot. They also argued that back pay wasn’t available because such damages would ultimately be paid by the city, contradicting Monroe’s holding that municipal corporations didn’t face section 1983 liability.
The district court found that the forced leaves were unconstitutional but held that injunctive relief was moot and back pay wasn’t available because it would circumvent municipal immunity. The Second Circuit affirmed, and the United States Supreme Court granted cert.
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