Monroe v. Pape
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| Monroe v. Pape | ||||||||||
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| Argued November 8, 1960 Decided February 20, 1961 |
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| Holding | ||||||||||
| Court membership | ||||||||||
| Chief Justice: Earl Warren Associate Justices: Hugo Black, Felix Frankfurter, William O. Douglas, Tom C. Clark, John Marshall Harlan II, William J. Brennan, Jr., Charles Evans Whittaker, Potter Stewart |
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| Case opinions | ||||||||||
| Majority by: Douglas Concurrence by: Harlan Joined by: Stewart Dissent by: Frankfurter |
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| Laws applied | ||||||||||
| Fourteenth Amendment, Section 1 of the "Ku Klux Act" of April 20, 1871 | ||||||||||
Monroe v. Pape, , was a United States Supreme Court case that considered the application of Federal Civil Rights law to constitutional violations by city employees.
The case arose when there was a complaint that police officers of the City of Chicago broke into the Monroes' home one night which the officers then ransacked while making the couple stand naked in the living room. Mr. Monroe was then taken downtown to the police station where he was interrogated concerning a two-day-old murder, while not being allowed to make a phone call or talk to a lawyer. He was later released. The officers did not have a search warrant or an arrest warrant.
The Monroes sued the police officers and the City of Chicago for violating their civil rights under §1983.
The City of Chicago moved to dismiss the complaint on the ground that it could not be held not liable under the Civil Rights Acts or for acts committed in performance of its governmental functions.
The Supreme Court dismissed the complaint against the city, finding that Congress had not intended the word "person" to in section 1983 to apply to municipalities.
Monroe was later overruled in Monell v. Department of Social Services of the City of New York, to the extent that local governments could be liable in federal court for violating individuals' constitutional rights.
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[edit] A Turbulent Time
In the years immediately following the Civil War, the southern United States suffered great social and political upheaval. Many white citizens resented the political power wielded by newly freed slaves, and took action to curb their participation in the electoral process through terror and other means. As attacks against African Americans continued into the 1870s, many of which were conducted with the approval and even the participation of local law enforcement authorities, President Ulysses S. Grant asked for congressional action to address the problem.
The Ku Klux Klan Act was passed in 1871 in response to Grant's appeal. When added to the U.S. Code as R.S. 1979, it provided in Section 1 that every person who, under color of any statute, ordinance, custom, or usage, of any State or Territory, subjects, or causes to be subjected, any citizen of the United States or other person within the jurisdiction thereof to the deprivation of any rights, privileges, or immunities secured by the Constitution and laws, shall be liable to the party injured in an action at law, suit in equity, or other proper proceeding for redress.
[edit] An Energetic Mistake
While investigating a murder, the Chicago police conducted a warrantless search of the Monroe home. Their search techniques were unorthodox. Thirteen police officers broke into the Monroe house in the early morning hours, made every family member get out of bed and stand naked in the center of the living room, and ransacked the house looking for evidence of Mr. Monroe's involvement in the murder. The search included such actions as emptying drawers onto the floor and the ripping open of mattresses. Mr. Monroe was then taken to the police station and detained for ten hours without specific charges being brought against him. He was not brought before a magistrate at the onset of his ordeal, as was legally required, despite the fact that one was available at the station where he was detained. He was also not allowed to contact his attorney during his detention. Despite all this activity, the police were unable to uncover any evidence linking Mr. Monroe to the murder they were investigating, and were forced to release him without bringing any criminal charges against him.
[edit] Impact
The ruling affirmed the right of citizens to seek compensation beyond exclusion of evidence for actions taken "under color of law" by state officials. Monroe v. Pape also confirmed the jurisdiction of the federal judiciary in cases where state courts failed to provide sufficient recompense to victims of civil rights infringements by state authorities. By stopping short of making municipalities liable for the actions of their officers, however, the Court failed to fully protect the rights of the individual. This was remedied in Monell v. Department of Social Services (1978), in which the Court went beyond Monroe to rule that individuals whose civil rights had been violated could seek redress from municipalities as well as from their officers.
