McMillian v. Monroe County, Alabama

Summary

The Court, in an opinion by Chief Justice Rehnquist joined by Justices O'Connor, Scalia, Kennedy, and Thomas, held that Alabama sheriffs represent the State, not their counties, when performing law enforcement duties. It therefore affirmed the dismissal of McMillian's § 1983 claims against Monroe County arising from Sheriff Tate's alleged misconduct. Policymaker status requires a function-specific inquiry informed by state law, rather than a categorical or nationally uniform classification of sheriffs. Justice Ginsburg dissented, joined by Justices Stevens, Souter, and Breyer, reasoning that local election, funding, territorial authority, and operational independence made Tate a county policymaker. She emphasized that the majority's Alabama-specific holding left county liability in other jurisdictions largely unchanged.