City of Los Angeles v. Heller,
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475 U.S. 796 (1986)
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U.S. Supreme Court
City of Los Angeles v. Heller, 475 U.S. 796 (1986)
City of Los Angeles v. Heller
Decided April 21, 1986
475 U.S. 796
Respondent was stopped by Los Angeles police officers, who suspected that he was driving while intoxicated, and was told that he was under arrest. When an officer attempted to handcuff him, an altercation developed and respondent fell through a plate-glass window. Respondent filed suit in Federal District Court under 42 U.S.C. § 1983, claiming damages from arrest without probable cause and from excessive force in the making of the arrest. During a bifurcated trial, his claims against the police officer were heard first, and the jury was instructed that respondent would make out his constitutional claim if he demonstrated he had been arrested without reasonable cause or with "unreasonable force" that exceeded the force necessary under the circumstances to effect arrest. The jury was not instructed on any affirmative defenses that might have been asserted by the officer. The jury returned a verdict for the officer, and the District Court dismissed the action against petitioners, the city and members of its Police Commission. The Court of Appeals reversed the judgment dismissing the case against petitioners, even though it did not disturb the verdict for the officer.
Held: The Court of Appeals erred in apparently basing its reversal on the grounds that the jury could have believed that the officer, having followed Police Department regulations, was entitled in substance to a defense of good faith, and that such a belief would not negate the existence of a constitutional injury. The jury was not charged on any affirmative defense that the officer might have had -- such as good faith and qualified immunity -- and the theory under which jury instructions are given, and reviewed on appeal, provides that juries act in accordance with the instructions given them, and do not base their decisions on legal questions as to which they are not charged. The jury's finding of no constitutional injury was conclusive not only as to the officer, but also as to petitioners. Petitioners were sued only because they were thought legally responsible for the officer's actions; if the latter inflicted no constitutional injury on respondent, petitioners cannot be liable in damages to respondent, regardless
of whether departmental regulations might have authorized the use of constitutionally excessive force.
Certiorari granted; 769 F.2d 1371, reversed and remanded.