Los Angeles County v. Humphries, 562 U.S. 29

Monell held municipalities liable under §1983 for policy or custom; the Court today extends that to prospective relief as well.
California’s Child Abuse and Neglect Reporting Act requires agencies to report unfounded or inconclusive child abuse findings to the Department of Justice, adding them to the Index for at least 10 years.
No procedures existed in California or Los Angeles County to review whether a report was unfounded or to challenge inclusion in the Index.
Two plaintiffs were exonerated from abuse accusations and sought removal from the Index, damages, injunctive/declaratory relief, and a procedural mechanism to contest inclusion.
The Ninth Circuit held Monell applied to prospective relief and remanded for further proceedings; the County appealed, arguing Monell applies only to damages, which this Court now rejects.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does Monell apply to §1983 claims for prospective relief?	Humphries: Monell’s policy or custom requirement should apply to prospective relief.	County: Monell applies only to damages, not prospective relief.	Yes, Monell applies to prospective relief.

Monell v. Dept. of Social Servs., 436 U.S. 658 (1978) (municipal liability for policy or custom under §1983; extends to injunctive/declaratory relief)
Monroe v. Pape, 365 U.S. 167 (1961) (municipal liability not initially a ‘person’ under §1983; later reconsidered)
Chaloux v. Killeen, 886 F.2d 247 (9th Cir. 1989) (prospective relief considerations in Monell context)
Truth v. Kent School Dist., 542 F.3d 634 (9th Cir. 2008) (limitations to liability; reliance on Monell principles)
Kenosha v. Bruno, 412 U.S. 507 (1973) (Congress did not intend generic ‘person’ to bifurcate liability by relief type)
Fitzgerald v. Barnstable School Comm., 555 U.S. 246 (2009) (uses 'custom, policy, or practice' phrasing in Monell context)