Rizzo v. Goode

423 U.S. 362 (1976)

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Nature of the Case

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Facts

Allegations were made against the Philadelphia police department regarding a pervasive pattern of illegal and unconstitutional treatment of minorities in particular and against all Philadelphia residents in general. Two trials were held to redress these alleged violations. The named individuals (Ds) were the city Mayor, the City Managing Director, and the Police Commissioner and they were charged with conduct ranging from express authorization or encouragement of the mistreatment to a failure to act in a manner so as to assure the victims that such treatment would not recur in the future. The trial at the District Court entailed 250 witnesses and 21 days of hearings over 40 off incidents. The District Court made detailed findings of fact, which both sides to the lawsuit accepted with respect to the Goode (P) incidents. In that incident, the court found that the officers’ conduct was violative of constitutional rights and that this had only resulted in one of the officers being given a five-day suspension and in another’s disposition that there was no basis for disciplinary action. However, in only two of the incidents recounted in COPPAR did the court find that the police conduct amounted to a deprivation of a federally secured right. No misconduct was found in five other incidents, but in 21 incidents the court made no comment at all. The court also found that the evidence did not establish the existence of any policy on the part of Ds to violate the constitutional rights of Ps as a class. The court did find that police department policy indicated there was a tendency to discourage the filing of civilian complaints against the police and to minimize the consequences of police misconduct. It also found that only a small percentage of policemen commit acts that violate constitutional rights but that the frequency of such violations was such that they could not be classified as rare or isolated events. The court then directed Ds to draft for court approval a comprehensive plan for dealing adequately with civilian complaints (the guidelines for that plan are listed on page 222 Re 5th edition.) The actions were brought under 42 USC 1983, and the equitable relief was fashioned under that same statute. Eventually, the program that was drafted was incorporated into a final judgment. The Court of Appeals affirmed the District Court. Ds appealed; the judgment of the District Court represents an unwarranted intrusion by the federal judiciary into the discretionary authority of local governments to perform their functions. The Supreme Court granted certiorari.