Michel v. Hartford, 226 Conn. App. 98 (2024)

Citation: Michel v. Hartford, 226 Conn. App. 98 (2024)
Parent Document: Michel v. Hartford, 226 Conn. App. 98 (2024)
Jurisdiction: Connecticut (state)
Effective Date: 2024-06-11
Original Source: https://www.courtlistener.com/opinion/10131855/michel-v-hartford/ ↗

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defendant’s policies, practices, or customs led to a viola-
tion of his constitutional rights, as required for munici-
pal liability. We are not persuaded.11
‘‘A municipality or other local government may be
liable under [§ 1983] if the governmental body itself
subjects a person to a deprivation of rights or causes
a person to be subjected to such deprivation. See Monell
v. New York City Dept. of Social [Services], 436 U.S.
658, 692 [98 S. Ct. 2018, 56 L. Ed. 2d 611] (1978) [quoting
42 U.S.C. § 1983]. But, under § 1983, local governments
are responsible only for their own illegal acts. . . .
They are not vicariously liable under § 1983 for their
employees’ actions. . . . Plaintiffs who seek to impose
liability on local governments under § 1983 must prove
that action pursuant to official municipal policy caused
their injury. . . .
‘‘[I]t is not enough for a § 1983 plaintiff merely to
identify conduct properly attributable to the municipal-
ity. The plaintiff must also demonstrate that, through
its deliberate conduct, the municipality was the moving
force behind the injury alleged. That is, a plaintiff must
show that the municipal action was taken with the
requisite degree of culpability and must demonstrate a
direct causal link between the municipal action and the
deprivation of federal rights. Where a plaintiff claims
that a particular municipal action itself violates federal
law, or directs an employee to do so, resolving these
issues of fault and causation is straightforward. . . .
Where [however] a plaintiff claims that the municipality
11
The plaintiff also contends that the court improperly concluded that he
failed to sufficiently allege that his speech was on a matter of public concern,
as required for protection under the first amendment. As set forth in part
II of this opinion, we agree with that contention. Nevertheless, the plaintiff’s
failure to plead sufficient facts to establish municipal liability is fatal to his
§ 1983 claim.
Moreover, in light of our conclusion as to municipal liability, we need
not reach the defendant’s alternative ground for affirmance that the plaintiff’s
§ 1983 claim is time barred by the statute of limitations.
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