City of St. Louis, Missouri, et al. v. Mary R. Meier

Every year, thousands of automobiles are identified in law enforcement databases as stolen or wanted in connection with crimes. Warrants for seizure of automobiles in public places on probable cause have never been required under the Fourth Amendment – yet the judgment of the Court of Appeals here imposes liability under 42 U.S.C. §1983 on petitioners due to a warrantless seizure of a truck pursuant to a “wanted” bulletin, notwithstanding probable cause to believe that the truck was evidence or an instrumentality of crime. The Court of Appeals also held that the practice of a towing contractor of a different jurisdiction, to detain automobiles seized pursuant to “wanted” bulletins issued by a different police agency, could result in liability of a city under §1983, notwithstanding that the private actor had no contractual relationship with and was not acting at direction of petitioner City. These holdings conflict with decisions of this Court and other Circuits. I. Whether a municipality, whose officers issued a “wanted” report supported by probable cause to believe that an automobile was an instrumentality or evidence of a crime, resulting in the seizure of an automobile by officers of another jurisdiction, can be held liable for a violation of the Fourth and Fourteenth Amendments, in an action by the vehicle’s owner under 42 U.S.C. §1983 for seizure of the automobile? II. Whether the “rigorous standards” of causation and culpability governing municipal liability under 42 U.S.C. §1983 permit such liability against a