McMILLIAN v. MONROE COUNTY, ALABAMA(1997)

No. 96-542

Argued: March 18, 1997Decided: June 2, 1997

After spending six years on Alabama’s death row, petitioner’s capital murder conviction was reversed on the ground that the State had suppressed exculpatory evidence. He then sued respondent Monroe County and others under 42 U.S.C. § 1983 for the allegedly unconstitutional actions of, inter alios, County Sheriff Tom Tate in suppressing the evidence. A county is liable under §1983 for those actions of its sheriff that constitute county “policy.” Monell v. New York City Dept. of Social Servs., 436 U.S. 658, 694 . The District Court dismissed the claims, holding that Tate’s unlawful acts did not represent Monroe County’s policy, because an Alabama county has no authority to make law enforcement policy. The Court of Appeals affirmed, agreeing that a sheriff acting in his law enforcement capacity is not a policymaker for the county.

Held: Alabama sheriffs, when executing their law enforcement duties, represent the State of Alabama, not their counties. Pp. 3-16.

(a) In determining a local government’s §1983 liability, a court’s task is to identify those who speak with final policymaking authority for the local governmental actor concerning the action alleged to have caused the violation at issue. Jett v. Dallas Independent School Dist., 491 U.S. 701, 737 . The parties agree that Sheriff Tate has final policymaking authority in the area of law enforcement, but they disagree about whether Alabama sheriffs are policymakers for the State or the county when acting in their law enforcement capacity. In deciding this dispute, the question is not whether Alabama sheriffs act as county or state officials in all of their official actions, but whom they represent in a particular area or on a particular issue. Ibid. This inquiry is dependent on the definition of the official’s functions under relevant state law. Cf. Regents of University of California v.Doe, 519 U. S. ___, ___. Pp. 3-5.

(b) The Court defers considerably to the Court of Appeals’ expertise in interpreting Alabama law, see Jett, supra, at 738, and concludes that the State’s constitutional provisions concerning sheriffs, the historical development of those provisions, and the interpretation given them by the State Supreme Court strongly support Monroe County’s contention that sheriffs represent the State when acting in their law enforcement capacity. The relevant portions of the Alabama Code, although less compelling, also support this conclusion. Code provisions cutting in favor of the conclusion that sheriffs are county officials are insufficient to tip the balance in petitioner’s favor. Pp. 5-13.

(c) The Court rejects petitioner’s arguments that the result here will create a lack of uniformity in Alabama–by allowing 67 county sheriffs to have different state law enforcement policies in their counties–and throughout the country–by permitting sheriffs to be classified as state officials in some States and county officials in others. The common law itself envisioned the possibility that state law enforcement “policies” might vary locally, as particular sheriffs adopted varying practices for arresting criminals or securing evidence. And the Nation’s federal nature allows the States wide authority to set up their state and local governments as they wish. Petitioner’s and his amici’s concern that state and local governments will manipulate local officials’ titles in a blatant effort to shield local governments from liability is foreclosed by St. Louis v. Praprotnik, 485 U.S. 112, 127 (per curiam). Pp. 13-16.

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