Johnson v. City of Shelby

Where a constitutional claim is levied directly against a municipality, there is no heightened pleading rule which requires plaintiffs seeking damages for civil rights violations to expressly invoke 42 U.S.C. §1983 in their complaint.

Petitioners, who worked for Respondent, alleged they were fired for bringing to light criminal activities of one of the aldermen on Respondent’s board. Petitioners alleged Respondents violated their Fourteenth Amendment due process rights and sought compensatory relief. The District Court entered summary judgement against Petitioners because they failed to invoke 42 U.S.C. §1983 in their complaint, and the Fifth Circuit affirmed.

The Supreme Court reversed and remanded, holding that there is no heightened pleading rule, which would require plaintiffs seeking damages for civil rights violations to expressly invoke §1983 to effectively state a claim. The Court reasoned that a “qualified immunity analysis” is unnecessary when a plaintiff asserts a constitutional claim against a city, rather than an agent.