LOS ANGELES COUNTY, CA v. HUMPHRIES

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Case Basics
Docket No. 
09-350
Petitioner 
Los Angeles County, CA
Respondent 
Craig and Wendy Humphries
Decided By 
Advocates
(for the petitioner)
(for the respondents)
Term:
Facts of the Case 

Craig and Wendy Humphries were accused of abuse by one of their children, arrested, and their children were taken away from them. They were charged with child abuse and felony torture, but the charges were dismissed once it became clear the allegations were not true. Despite the fact that the charges were dismissed, the Humphries were placed on California's Child Abuse Central Index ("CACI") – a database for known and suspected child abusers. The Humphries subsequently filed suit against Los Angeles County and various County officials in a California federal district court. The Humphries argued that California's maintenance of the CACI violates the Due Process Clause of the Fourteenth Amendment because identified individuals are not given fair opportunity to challenge the allegations against them. The district court dismissed their claims.

On appeal, the U.S. Court of Appeals for the Ninth Circuit reversed holding that the erroneous listing of the Humphries on the CACI violated the Due Process Clause of the Fourteenth Amendment. The Humphries, as the prevailing party, then moved for attorneys' fees. The Ninth Circuit awarded the fees, reasoning that the limitations to liability established in Monell v. Department of Social Services do not apply to claims for declaratory relief.

Question 

Are claims for declaratory relief against a local public entity subject to the requirement of Monell that the plaintiff must demonstrate that the constitutional violation was the result of the policy, custom, or practice attributable to the local public entity; or are such claims exempt as determined by the Ninth Circuit?

Conclusion 
Decision: 8 votes for Los Angeles County, 0 vote(s) against
Legal provision: U.S. Constititution, Amendment XIV, Due Process Clause

The Supreme Court reversed and remanded the Ninth Circuit decision, holding that Los Angeles County does not have to pay attorneys' fees in the case. Justice Stephen Breyer, who wrote the 8-0 opinion for the court, reasoned that the court’s ruling in Monell applies to claims against municipalities for prospective relief as well as to claims for damages. Justice Elena Kagan did not take part in the consideration and decision of the case because she worked on it while in the solicitor general's office.

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LOS ANGELES COUNTY, CA v. HUMPHRIES . The Oyez Project at IIT Chicago-Kent College of Law. 25 November 2014. <http://www.oyez.org/cases/2010-2019/2010/2010_09_350>.
LOS ANGELES COUNTY, CA v. HUMPHRIES , The Oyez Project at IIT Chicago-Kent College of Law, http://www.oyez.org/cases/2010-2019/2010/2010_09_350 (last visited November 25, 2014).
"LOS ANGELES COUNTY, CA v. HUMPHRIES ," The Oyez Project at IIT Chicago-Kent College of Law, accessed November 25, 2014, http://www.oyez.org/cases/2010-2019/2010/2010_09_350.