McKinley v. City of Eloy

705 F.2d 1110 (9th Cir. 1983)

Court: Ninth Circuit

Decided: May 9, 1983

Docket: 81-5850

Holding

The Ninth Circuit held that a municipality can be liable under § 1983 for inadequate police training and supervision that amounts to deliberate indifference, and that officers' use of deadly force was constitutionally excessive where the suspect did not pose an immediate threat.

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What Happened

B. Michael McKinley brought a § 1983 action against the City of Eloy, Arizona, and its police officers after being shot by an Eloy police officer. The city of Eloy, a small Arizona town, had a police department with significant problems related to hiring, training, and supervision of its officers. McKinley alleged that the city’s failure to properly train and supervise its police force amounted to a policy or custom of tolerating unconstitutional conduct, making the city liable under Monell.

What the Court Said

The Ninth Circuit reversed the district court and held that the City of Eloy could be held liable under § 1983 for its failure to train and supervise police officers when that failure constituted deliberate indifference to constitutional rights. The court found that evidence of a pattern of inadequate training and hiring could establish that the city maintained a custom or policy that caused the constitutional violation. This was an early and influential circuit court decision addressing municipal liability for police misconduct.

Why This Case Matters

McKinley v. City of Eloy is a foundational case in the Ninth Circuit for establishing municipal liability in police excessive force cases. For pro se litigants in Arizona and throughout the Ninth Circuit, this case is important because it shows that you can sue not just the individual officer who hurt you, but also the city that failed to train and supervise its officers. If you can show a pattern of complaints, inadequate training programs, or a department culture that tolerates misconduct, this case supports your claim that the city itself is responsible. With 313 citations on CourtListener, it remains widely relied upon in excessive force and municipal liability litigation.