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Monroe v. Pape

Equal Protection And The States

The Court ruled unanimously in favor of the petitioners, deciding that they had legal grounds to pursue redress through civil litigation against the police officers responsible for their ordeal. The ruling did not extend to the city of Chicago, however, as the Court interpreted R.S. 1979's second clause as exempting municipalities from liability for the actions of their officers. Justice Douglas, writing for the Court, observed that federal jurisdiction certainly was present in the case, since Fourth Amendment prohibitions against unreasonable searches and seizures are made applicable to the states through the Due Process Clause of the Fourteenth Amendment. Furthermore, although R.S. 1979 was originally created to protect African Americans from the Ku Klux Klan, it was also designed to ensure that the states enforced their own laws equally with regard to all their citizens. In the present case, the actions of police officers were judged to be so egregious that the exclusion of evidence obtained through their searches (of which there was none in any case) could not possibly recompense the Monroe family for its trouble. Finally, since the state courts were unable to provide any compensatory action to the Monroe family, a federal remedy had to be forthcoming.

Significantly, despite the appearance of a clear victory for the petitioners, the Court's refusal to allow the city of Chicago to be sued would continue to pose a legal barrier to individuals seeking redress for misdeeds of municipalities that could not be compensated for through mere exclusion of evidence.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1954 to 1962Monroe v. Pape - Significance, A Turbulent Time, An Energetic Mistake, Equal Protection And The States, Impact