Monroe v. Pape, 365 U.S. 167 (1961)

E403301

Section 1983 case United States Supreme Court case civil rights case

Monroe v. Pape, 365 U.S. 167 (1961), is a landmark U.S. Supreme Court decision that broadly expanded the scope of civil rights lawsuits against state and local officials under 42 U.S.C. § 1983, allowing individuals to sue for constitutional violations even when the officials’ actions were unauthorized by state law.

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All labels observed (2)

Label	Occurrences
Monroe v. Pape, 365 U.S. 167 (1961) canonical	1
Monroe v. Pape, 365 U.S. 167 (1961), in part	1

Statements (49)

Predicate	Object
instanceOf	Section 1983 case ⓘ United States Supreme Court case ⓘ civil rights case ⓘ
appliesTo	local officials ⓘ police officers ⓘ state officials ⓘ
areaOfLaw	civil rights law ⓘ constitutional law ⓘ federal courts ⓘ
citation	365 U.S. 167 ⓘ
constitutionalRightInvolved	Fourth Amendment rights as incorporated through the Fourteenth Amendment ⓘ
court	Supreme Court of the United States ⓘ
decisionDate	1961 ⓘ
defendant	Ben Pape ⓘ Chicago police officers ⓘ
dissentBy	Charles E. Whittaker ⓘ
effectOnLaw	Expanded the interpretation of "under color of" state law to include misuse of power possessed by virtue of state law. ⓘ
effectOnLitigation	Led to a substantial increase in Section 1983 lawsuits in federal courts. ⓘ
factualBackground	Chicago police officers allegedly conducted an early-morning, warrantless, and abusive search of the Monroe home and detained James Monroe without proper legal process. ⓘ
fullCaseName	James Monroe et al. v. Ben Pape et al. ⓘ
historicalSignificance	The case is considered a foundational decision in modern Section 1983 jurisprudence. ⓘ The decision encouraged the use of federal courts to vindicate constitutional rights against state and local officials. ⓘ The decision greatly expanded the availability of federal civil rights lawsuits against state and local officials. ⓘ
holding	A municipality is not a "person" within the meaning of 42 U.S.C. § 1983 and therefore is not subject to suit for damages under that statute. ⓘ Actions taken by state and local officials under color of state law can give rise to liability under 42 U.S.C. § 1983 even if those actions are not authorized by state law. ⓘ Exhaustion of state judicial remedies is not a prerequisite to bringing a Section 1983 action in federal court. ⓘ Section 1983 provides a federal cause of action for damages for violations of constitutional rights by state and local officials acting under color of state law. ⓘ
issue	Whether a municipality is a "person" subject to suit under 42 U.S.C. § 1983. ⓘ Whether plaintiffs must exhaust state remedies before bringing a Section 1983 action in federal court. ⓘ Whether police officers who violate the Constitution while acting under color of state law can be sued for damages under 42 U.S.C. § 1983 even when their conduct is unauthorized by state law. ⓘ
jurisdiction	federal question jurisdiction ⓘ
keyConcept	federal cause of action for constitutional violations ⓘ municipal liability under Section 1983 ⓘ non-exhaustion of state remedies in Section 1983 actions ⓘ under color of state law ⓘ
laterOverruledInPartBy	Monell v. Department of Social Services, 436 U.S. 658 (1978) ⓘ
legalProvisionInterpreted	42 U.S.C. § 1983 ⓘ Due Process Clause ⓘ surface form: Due Process Clause of the Fourteenth Amendment Fourteenth Amendment ⓘ surface form: Fourteenth Amendment to the United States Constitution
majorityOpinionBy	William J. Brennan Jr. ⓘ
overruledAspect	The holding that municipalities are not "persons" under 42 U.S.C. § 1983 was overruled by Monell v. Department of Social Services. ⓘ
plaintiff	James Monroe ⓘ
relatedCase	The Civil Rights Cases (1883) ⓘ surface form: Civil Rights Cases, 109 U.S. 3 (1883) Monell v. Department of Social Services, 436 U.S. 658 (1978) ⓘ Screws v. United States ⓘ surface form: Screws v. United States, 325 U.S. 91 (1945)
remedyType	damages ⓘ
statutoryContext	Civil Rights Act of 1871 ⓘ surface form: Ku Klux Klan Act of 1871 Reconstruction-era civil rights legislation ⓘ
vote	8–1 decision ⓘ

Referenced by (2)

Full triples — surface form annotated when it differs from this entity's canonical label.

42 U.S.C. § 1983 → interpretedBy → Monroe v. Pape, 365 U.S. 167 (1961) ⓘ

Monell v. Department of Social Services, 436 U.S. 658 (1978) → overruledPrecedent → Monroe v. Pape, 365 U.S. 167 (1961) ⓘ

this entity surface form: Monroe v. Pape, 365 U.S. 167 (1961), in part