San Juan County, Utah v. Rosalie Chilcoat

A prosecutor in San Juan County, Utah, acted on behalf of the State of Utah when he made allegedly false statements at the preliminary hearing in the State’s prosecution of Rosalie Chilcoat. The County, therefore, could not be held liable under 42 U.S.C. § 1983 for the prosecutor’s unconstitutional actions as alleged in Ms. Chilcoat’s complaint. So held the United States Court of Appeals for the Tenth Circuit in the proceedings below, affirming the district court’s ruling. But a majority of the Tenth Circuit panel reversed the district court’s decision denying Ms. Chilcoat leave to amend her complaint to allege that the County involved itself in Ms. Chilcoat’s prosecution at a secret meeting among the County commissioners and the County Sheriff, holding that the allegation supported a plausible municipal liability claim. The district court had denied the proposed amendment on futility grounds. The question thus presented is whether a municipality may be exposed to liability under Section 1983 and Monell v. Dep’t of Soc. Servs. of City of New York, 436 U.S. 658 (1978), if municipal officials influence a State actor’s decision to take an unconstitutional action, even where the municipality lacks authority to make that decision itself.