California Court of Appeal Holds That Officer Who Did Not Facilitate Wrongful Conduct For Which He Was Unaware Was Not Liable for Section 1983 Violation
Trinidad Macias appeals from summary judgment entered against him on his complaint for violation of his civil rights pursuant to 42 U.S.C. section 1983. The complaint alleged that a number of deputies of the Los Angeles County Sheriff's Department executed a search warrant at Macias' home in an unreasonable manner. The trial court granted summary judgment on the ground that Macias failed to introduce evidence showing there was a violation of a constitutional right. The Court of Appeal reversed the ruling of summary judgment as to some of the officers and upheld the judgment as to other officers who were not "integral participants" in the violation of Macias' constitutional rights.
The Court explained that in order for an officer to be liable for the violation of Macias' constitutional rights, that officer must have been either personally involved in that violation or an "integral participant" in the conduct giving rise to the violation. (Jones v. Williams, 297 F.3d 930, 936 (9th Cir. 2002)("[e]ither integral participation or personal involvement was required before a jury could find officers liable.") The Court further noted that the federal case law discussing what constitutes integral participation is not uniform. Some courts have held that an integral participant must be aware of the unlawful conduct or facilitate the conduct itself, whereas other courts have taken an even broader view and have held that every officer who participated in the illegal search, irrespective of whether or not all of the officers were aware of the search. The Court found the narrow approach more persuasive and held that there was no basis for imposing liability on officers for unplanned conduct that they did not engage in or facilitate themselves, and of which they were not even aware.
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