City of Los Angeles v. Heller

In City of Los Angeles v. Heller (1986) 475 U.S. 796, there were two sets of claims. The plaintiff's first claim was against an individual police officer for making an arrest without probable cause and using excessive force. (Id. at p. 797.) The plaintiff's second claim was against the city and its police commission for implementing policies which led to the violation of the plaintiff's constitutional rights. (Id. at pp.797, 799.) The liability of the individual officer and the Monell v. Department of Social Services of City of New York (1978) 436 U.S. 658 claim were tried separately. The jury found in favor of the individual police officer. The Ninth Circuit Court of Appeals held that the Monell claim was not foreclosed by the jury verdict exculpating the individual officer. (Id. at p. 799.) The Supreme Court disagreed and held: "But this was an action for damages, and neither Monell v. New York City Dept. of Social Services, , supra, 436 U.S. 658, 56 L. Ed. 2d 611 , nor any other of our cases authorizes the award of damages against a municipal corporation based on the actions of one of its officers when in fact the jury has concluded that the officer inflicted no constitutional harm. If a person has suffered no constitutional injury at the hands of the individual police officer, the fact that the departmental regulations might have authorized the use of constitutionally excessive force is quite beside the point." (City of Los Angeles v. Heller, supra, 475 U.S. at p. 799.)