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Civil rights Keyed to Jeffries, 5th Ed.
Monell v. Department of Social Services
Citation:
436 U.S. 658 (1978)Facts
The plaintiffs, female employees of the Department of Social Services and the Board of Education of New York City, brought a class action under § 1983 alleging that the defendants had unconstitutionally forced pregnant employees to take unpaid leaves of absence before such leaves were medically necessary. The city had a policy requiring pregnant employees to take maternity leave after the fifth month of pregnancy regardless of their ability to work. After the lawsuit was filed, the defendants changed their policies to allow pregnant employees to work as long as they were able. The District Court found the prior policy unconstitutional but denied backpay, holding that municipalities were immune from damages under § 1983 based on Monroe v. Pape. The Court of Appeals affirmed, ruling that neither the Board of Education nor individuals sued in their official capacities could be held liable for damages that would ultimately be paid by the city.
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