Court of Appeals Update - April 2025: Municipal Liability Under § 1983
- Reza Yassi
- Jun 6, 2025
- 2 min read
Updated: Jul 3, 2025
Quick Answer
The Court held that a municipality may be liable under 42 U.S.C. § 1983 only for its own policy or custom—not solely for the misconduct of individual officers.
Decision at a Glance
Decision: Maharaj v. City of New York — Court of Appeals — 2025 NY Slip Op 02143 — decided April 15, 2025.
Facts: Plaintiff alleged false arrest and excessive force by NYPD officers, claiming the City maintained an unconstitutional policy of inadequate training and supervision.
Procedural Posture: The trial court dismissed, concluding plaintiff failed to plead an actionable municipal policy; the Appellate Division affirmed.
Holding: Affirmed dismissal. To hold a municipality liable, plaintiff must allege a concrete policy, custom, or failure to train closely linked to the violation—not solely the officers’ misconduct.
Full Opinion: Read the full opinion here
Why This Case Matters
This decision reinforces the high bar for § 1983 municipal-liability claims, emphasizing that isolated incidents—even egregious—cannot by themselves establish city responsibility.
Client Question
“Can I sue the City of New York if an NYPD officer violated my civil rights?”
Your Answer
You can sue the individual officer under § 1983, but to sue the City itself, you must show the violation resulted from a formal policy or widespread custom—such as a failure to train—directly causing your harm.
FAQs
What is a “custom” under § 1983?
A practice so persistent and widespread it has the force of law.
Can a single incident trigger municipal liability?
No—§ 1983 requires systemic policy or custom, not isolated officer misconduct.
What evidence supports a failure-to-train theory?
Records of prior complaints, training materials, or expert testimony showing inadequate instruction.
Action Steps & Key Takeaways
Collect all police reports, internal complaints, and training manuals.
Identify any similar prior incidents suggesting a pattern.
Consult civil-rights counsel experienced in § 1983 litigation.
Next Steps
Gather documentation on prior incidents. Let’s discuss whether your case meets the policy-or-custom threshold for municipal liability.
Reza Yassi, Esq.
Admitted: NY, NJ, Federal Courts
📞 (646) 992-2138 · 📧 ry@yassilaw.com · 🌐 yassilaw.com
Disclaimer:
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