James Monroe sued the city of Chicago and two individual police officers for violating his civil rights after they entered and searched his home without a warrant and arrested and interrogated him without permitting him access to an attorney. Monroe’s suit was brought under 42 U.S.C. §1983, which was derived from the Civil Rights Act of 1871. After the U.S. district court dismissed the complaint and the U.S. court of appeals affirmed, the Supreme Court reviewed the case and reversed with respect to the individual officers. The Court held that while municipalities could not be liable under the Civil Rights Act, individuals acting “under color of law” could be sued for damages for denying the constitutional rights of individuals. Civil rights suits filed under Section 1983 became one of the largest sources of federal court business in the late twentieth century. Between 1871 and 1920, there were only 21 cases decided based on the statute, but in 1995 there were more than 57,000.

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