City of Oklahoma City v. Tuttle (1984)
- Docket
- 83-1919
- Decided
- 1984-01-01
Summary
Question: Does a single, isolated incident of the use of excessive force by a police officer establish an official policy or practice of a municipality that renders it liable for damages under Section 1983? Conclusion: No. Justice William H. Rehnquist delivered the opinion for the four-justice plurality. The plurality held that the district court’s instructions to the jury improperly allowed a plaintiff to impose liability on the city without proof of a single action taken by a municipal policy maker. The plurality further concluded that proof of a single incident of unconstitutional activity is not sufficient to impose liability on a city for a policy that is not in and of itself unconstitutional. Justice William J. Brennan, Jr. wrote an opinion concurring in part and concurring in the judgment in which he argued that Section 1983 does not permit a city to be held liable on a theory of strict responsibility for its non-policy-making employees. Instead, municipalities are liable for constitutional deprivations caused by an official policy or custom. Because the jury could have found the city liable solely because the police officer’s actions were so excessive and out of the ordinary, Justice Brennan concurred with the judgment reached by the Court. Justice Thurgood Marshall and Justice Harry A. Blackmun joined in the opinion concurring in part and concurring in the judgment. Justice John Paul Stevens wrote a dissent in which he argued that cities should be held liable under Section 1983 for the unconstitutional acts of their agents that are performed in the court of their official duties.