United States v. County of Maricopa, No. 15-17558 (9th Cir. 2018)
Annotate this CaseThe proper standard for determining which employees have the power to establish an entity's "official policy" under Title VI of the Civil Rights Act of 1964 and 34 U.S.C. 12601 is the standard that governs under 42 U.S.C. 1983. The Ninth Circuit affirmed the district court's grant of summary judgment for the government in an action brought to halt racially discriminatory policing policies concerning traffic stops instituted by Joseph Arpaio, the former Sheriff of Maricopa County, Arizona. The panel held that Arpaio acted as a final policymaker for the County; the County was liable for violations of Title VI and section 12601 stemming from its own official policies; and Arpaio adopted the racially discriminatory traffic-stop policies at issue, he acted as a final policymaker for the County, and the district court correctly held the County liable for the violations of Title VI and section 12601 caused by those policies. The panel also held that the district court properly applied issue preclusion to bar the County from relitigating the lawfulness of Arpaio's traffic-stop policies in light of prior adverse findings in Melendres v. Arpaio, 695 F.3d 990 (9th Cir. 2012).
Court Description: Civil Rights. The panel affirmed the district court’s summary judgment in favor of the United States, which brought this action to halt racially discriminatory policing policies concerning traffic stops instituted by Joseph Arpaio, the former Sheriff of Maricopa County, Arizona. The panel held that Sheriff Arpaio acted as a final policymaker for the County. The panel further held that because the traffic-stop policies at issue fell with the scope of a sheriff’s law-enforcement duties, Arpaio acted as a final policymaker for Maricopa County when he instituted those policies. The panel held that Title VI of the Civil Rights Act of 1964 and 34 U.S.C. § 12601 authorized policymaker liability. The panel further held that the proper standard for determining which employees have the power to establish an entity’s “official policy” under Title VI and 34 U.S.C. § 12601 is the standard that governs under 42 U.S.C. § 1983. The panel concluded that Maricopa County was liable for UNITED STATES V. COUNTY OF MARICOPA 3 violations of Title VI and § 12601 stemming from its own official policies. Finally the panel held that when Arpaio adopted the racially discriminatory traffic-stop policies at issue, he acted as a final policymaker for the County, and the district court correctly held the County liable for the violations of Title VI and § 12601 caused by those policies. The panel held that the district court properly applied issue preclusion to bar the County from relitigating the lawfulness of Arpaio’s traffic-stop policies because the County was bound by prior adverse findings. See Melendres v. Arpaio, 695 F.3d 990 (9th Cir. 2012).
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.