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Board of Commissioners of Bryan County v. Brown

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Board of Comm'rs of Bryan Cty. v. Brown
Seal of the United States Supreme Court
Argued 5 November, 1996
Decided 28 April, 1997
Full case nameBoard of the County Commissioners of Bryan County, Oklahoma v. Brown, et al.
Citations520 U.S. 397 (more)
520 U.S. 397
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
David Souter · Clarence Thomas
Ruth Bader Ginsburg · Stephen Breyer
Case opinions
MajorityO'Connor, joined by Rehnquist, Kennedy, Scalia, Thomas
DissentSouter & Breyer, joined by Stevens, Ginsburg
Laws applied
Fourteenth Amendment, Section 1 of the "Ku Klux Act" of 20 April 1871 (codified at 42 U.S.C. § 1983)

Board of Commissioners of Bryan County v. Brown, 520 U.S. 397 (1997) was a United States Supreme Court case that considered the amount of proof necessary to hold a municipality liable under 42 U.S.C. § 1983 under a "deliberate indifference" theory. This case is significant in that it sets out specific guidelines for § 1983 plaintiffs who sue a city, county, or local government directly for actions or inactions taken by an official. Additionally, the case follows other § 1983 litigation like Monroe v. Pape and Monell v. Department of Social Services of the City of New York.

Syllabus[edit]

Jill Brown brought a damages action against Bryan County alleging that its Deputy Stacy Burns had arrested her with excessive force, and that it was liable for her injuries because its Sheriff B. J. Moore had hired Burns without adequately reviewing his background. Burns had pleaded guilty to various driving infractions and other misdemeanors, including assault and battery. Moore, whom the county stipulated was its Sheriff's Department policymaker, testified that he had obtained Burns' driving and criminal records, but had not closely reviewed either before hiring Burns.[1]

The District Court denied the county's motions for judgment as a matter of law, which asserted that a policymaker's single hiring decision could not give rise to § 1983 municipal liability. Respondent prevailed following a jury trial, and the Fifth Circuit affirmed, holding that the county was properly found liable based on Moore's decision to hire Burns.[1]

Holding[edit]

In a 5-4 decision, authored by Justice Sandra Day O'Connor, the Court ruled that municipalities are not liable for hiring employees who violate someone's rights unless a reasonable policymaker would conclude that the "plainly obvious consequence . . . would be the deprivation of a third party's federally protected rights. Thus, the county was not financially liable for Sheriff Moore's isolated decision to hire Burns without adequate screening because Brown had not proved that the decision reflected a conscious disregard for a risk that Burns would use excessive force in violation of her federally protected rights.[1][2]

References[edit]

  1. 1.0 1.1 1.2 "Board of the County Commissioners v. Brown, 520 U.S. 397 (1997)". This article incorporates text from this source, which is in the public domain.
  2. "Board of Comm'rs of Bryan Cty. v. Brown". Oyez.


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