Summary of Monroe v. Pape
Citation: 365 U.S. 167
Relevant Facts: On October 29, 1958, at 5:45 a.m., thirteen police officers, including Pape, conducted a search of James Monroe’s Chicago apartment. The officers broke down the door, made Monroe and his wife to stand in their living room (naked), and essentially wrecked the apartment while conducting their search. After the search/raid, Monroe was taken to the police headquarters and held for ten hours on “open" charges, during which time he was interrogated about a homicide. The police neither had a warrant for the search of Monroe’s home nor Monroe’s arrest but executed each regardless. Monroe requested, but was refused access to a telephone in order to call his attorney. Consequently, Monroe filed a complaint against each of the police officers as well as the City of Chicago, arguing that his civil rights had been violated. The City moved to have the complaint dismissed based on the fact that it was not liable under the Civil Rights Act. The district court dismissed Monroe’s complaint. On appeal, the 7th Circuit Court of Appeals affirmed the district court’s ruling to dismiss the complaint. The matter was appealed to and heard by the United States Supreme Court.
Issues: Two legal questions were presented. The first was whether an individual has a legitimate cause of action under the regulations of the Civil Rights Act, when a claim is brought against municipal workers (police officers), for a violation of Fifth Amendment (due process) rights? The second was whether municipalities can be liable (sued) under the Civil Rights Act.
Holding: The Supreme Court answered in the affirmative for the first question, and in the negative for the second.
Reasoning: The Court reasoned that the officers had egregiously conducted an unreasonable search and seizure under the color of the law, so, the officers could be held individually under the Act. But, such liability could only be applied to the individual officers and not the City of Chicago itself. The Court reasoned that when Congress created the Act, the intention for the classification of “person" was to reference an individual and not a municipality.
Conclusion: This case was especially important because the Court established the fact that municipal workers acting in their official capacities could be sued for conduct that violated the constitutional rights of others. In this particular case, there was no legal excuse for the police officers’ (mis)deeds. The ruling also effectively put municipal workers on notice that they could and likely would be sued by individuals whom believed them to have violated their rights, and such suits would not be automatically dismissed.