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City of St. Louis v. Praprotnik

United States Supreme Court

485 U.S. 112 (1988)

Relevant factsFree

After architect James Praprotnik (plaintiff) successfully appealed a suspension and a denied transfer to the city's Civil Service Commission (CSC), he was later laid off due to budget cuts and sued under § 1983, alleging the transfer and layoff were retaliatory, naming the city and individual officials including his supervisor Frank Hamsher. A jury cleared the individual officials but found the city liable for First Amendment retaliation, and the Eighth Circuit affirmed, reasoning the officials who made the employment decisions were policymakers whose final decisions bound the city regardless of the CSC's limited scope of review.

IssueFree

Whether a municipality may be held liable under § 1983 for the actions of its officials without proof that the officials acted pursuant to an unconstitutional municipal policy.

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