Los Angeles County v. Humphries, 131 S. Ct. 447

California statute requires agencies to report and include unfounded child-abuse reports in the State's Index for at least 10 years, but no procedures exist to review or challenge inclusion.
Humphries exonerated but remained on the Index; the Index is accessible to state agencies.
Plaintiffs filed a §1983 action seeking damages, an injunction, and declaratory relief for lack of a mechanism to contest Index inclusion.
District Court granted summary judgment; Ninth Circuit held notice and a hearing were constitutionally required and that the county potentially liable for fees under Monell.
Supreme Court holds that Monell's policy-or-custom requirement applies to §1983 claims for both monetary and prospective relief, reversing the Ninth Circuit and remanding for proceedings consistent with this opinion.
The decision relies on Monell (municipal liability only for own violations) and Monroe's history, applying that logic to prospective relief as well.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Monell apply to §1983 claims for prospective relief?	Humphries contends yes, Monell governs all §1983 liability.	County contends Monell applies only to monetary damages.	Yes; Monell applies to prospective relief as well.
Can a municipality be liable under §1983 for its own policy or custom when relief is prospective?	Yes, the policy-or-custom standard encompasses both damages and prospective relief.	Liability should depend on state policy rather than county policy.	Liability exists where a municipality's own policy or custom inflicts the injury, regardless of relief form.
Does the causation standard under §1983 tie to the form of relief sought?	Form of relief does not change the causation requirement.	Causation may be interpreted differently for remedies other than damages.	Causation requirement applies irrespective of whether relief is monetary or prospective.

Monroe v. Pape, 365 U.S. 167 (1961) (held municipalities not 'persons' under §1983 based on historical context; later overruled by Monell to allow municipal liability for own violations)
Monell v. New York City Dept. of Social Servs., 436 U.S. 658 (1978) (established policy-or-custom basis for municipal §1983 liability; applies to damages and, as held here, prospective relief)
Chaloux v. Killeen, 886 F.2d 247 (9th Cir. 1989) (supported view that Monell's requirement may not apply to certain prospective-relief claims)