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Leatherman v. Tarrant County Narcotics Intelligence Unit

Supreme Court of the United States · 1993 · Civil Procedure

pleadingheightened pleadingSection 1983municipal liabilityCivil ProcedureRule 8(a)Rule 9(b)notice pleading

Facts

The case arose from two incidents in which local law enforcement officers forcibly entered homes while executing search warrants based on detected odors associated with narcotics manufacture. One homeowner alleged officers assaulted him after entry, and another alleged officers entered her home in her absence and killed her two dogs. The plaintiffs sued local officials in their official capacity, the county, and two municipal corporations, alleging Fourth Amendment violations. As the basis for municipal liability under Section 1983, they alleged that the municipalities had failed adequately to train the officers involved.

Issue

May a federal court require a plaintiff asserting municipal liability under 42 U.S.C. Section 1983 to satisfy a heightened pleading standard more demanding than Rule 8(a)'s ordinary notice-pleading requirement? More specifically, can courts impose such a standard on Monell claims alleging municipal liability based on failure to train?

Rule

A complaint alleging municipal liability under Section 1983 is subject to the ordinary pleading requirement of Rule 8(a)(2): a short and plain statement showing that the pleader is entitled to relief. Federal courts may not impose a judicially created heightened pleading standard for such claims, because Rule 9(b) specifies the limited categories requiring particularity and does not include Section 1983 municipal-liability claims.

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In federal court in Ohio, Dana Ruiz sued the City of Toledo under 42 U.S.C. § 1983 after city police allegedly searched her apartment without probable cause. Her complaint alleges that the officers violated the Fourth Amendment and that the city maintained a policy or custom of inadequate supervision and training that caused the violation, but it does not set out detailed internal city practices.

The city moves to dismiss, arguing that a municipal-liability claim under § 1983 must be pleaded with factual particularity because ordinary notice pleading is too lenient. How should the court rule?

Explanation. A federal court may not impose a judicially created heightened pleading standard on § 1983 claims alleging municipal liability. Under the majority opinion, such claims are governed by Rule 8(a)(2), which requires only a short and plain statement giving fair notice of the claim and its grounds. Municipalities may be sued under § 1983, and the absence of detailed factual allegations does not justify dismissal solely for failure to satisfy a heightened standard. (Derived from Leatherman v. Tarrant County Narcotics Intelligence Unit (1993).)