42 U.S.C. § 1983

Section 1983 requires a plaintiff seeking damages for a death to prove by a preponderance of the evidence that the alleged indifference proximately caused the death.

Weathers v. Lanier · filed 2008-06-02

Because Weathers has not demonstrated proximate cause by a preponderance of the evidence, we need not consider whether Defendants acted with deliberate indifference to Raynell’s serious medical needs.

Section 1983 requires the plaintiff to show that the challenged conduct was a substantial or motivating factor in the injury; the defendant may then show by a preponderance of the evidence that the same result would have occurred without it.

Anderson v. City of New York · filed 1985-05-21

Specifically, plaintiff must first make a showing that the challenged conduct was a “substantial” or “motivating” factor in causing the injury. Then defendants must show, by a preponderance of the evidence, that the same result would have been reached even without the impermissible conduct.

A Section 1983 claim based on a federal statutory violation requires the alleged violation to proximately cause the plaintiff’s harm.

M.K. Ex Rel. Mrs. K. v. Sergi · filed 2008-06-06

Thus, even assuming that Putnam had failed to put in place the necessary support services to allow M.K. to return to the Putnam schools, this alleged violation of the IDEA could not be the proximate cause of any harm suffered by M.K., since M.K. was unwilling to return home from his residential placement in West Springfield. ... Therefore, the Court finds that plaintiffs have failed to establish an actionable § 1983 claim for defendants’ violation of the IDEA.

Section 1983 requires a public official to have caused the plaintiff’s constitutional deprivation to be liable.

Hernandez v. Carbone · filed 2008-07-29

Mr. Hernandez’s monetary claim against Mr. Carbone — “[a] public official is liable under § 1983 only if he caused the plaintiff to be subjected to a deprivation of his constitutional rights.” ... In the circumstances of this case, therefore, any chain of causation between Mr. Carbone’s allegedly unconstitutional policies and Mr. Hernandez’s alleged harm is broken as a matter of law.

Section 1983 requires a causal connection between the defendant’s conduct and the alleged deprivation; a complaint showing none may be dismissed for failure to state a claim.

Morton v. Becker · filed 1986-06-06

If it appears from the complaint, including its reasonable inferences, that there is no causal connection between the alleged deprivations and the challenged conduct, the complaint may properly be dismissed for failure to state a claim.

Section 1983 requires a causal connection between the defendant’s conduct and the plaintiff’s injury; independent inmate retaliation can break that connection.

Sheets v. Indiana Department of Corrections · filed 1986-12-31

Despite the fact that a duty has been shown, and assuming defendants breached such duty and plaintiffs suffered actual damage, plaintiffs have nonetheless failed to state a claim sufficient to defeat a 12(b)(6) motion, as a causal connection cannot, as a matter of law, be shown between the defendants’ breach of their duty and plaintiffs’ injury. ... The prisoners were not the agents of the defendants, and the prisoners’ actions were a substantial intervening force, even assuming that the defendants had a policy of prisoner beatings.

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Brooks v. Fitzsimmons · filed 1987-04-28

A plaintiff in a 1983 action must show the conduct of the defendant caused plaintiff to suffer the injury he complains of. ... Brooks suffered no deprivation in the sense that the conduct of the defendants did not "appreciably increase the probability" of Brooks' misidentifi-cation.

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Emmert Industrial Corp. v. City of Milwaukie · filed 2009-01-07

Thus, the waiver was not the actual or proximate cause of Emmert’s injury. Emmert cannot show the causation element required in a § 1983 action.

Section 1983 requires an affirmative causal connection between a particular defendant’s actions under color of state law and the constitutional deprivation.

Jenkins v. Dekalb County, GA · filed 2009-01-15

Causation demands “proof of an affirmative causal connection between the actions taken by a particular person ‘under color of state law’ and the constitutional deprivation.”

Section 1983 requires a policy or custom to proximately cause the claimed injury.

Whittington v. King County Department of Corrections · filed 2009-01-15

Whittington failed to raise a genuine issue of material fact as to whether unsanitary conditions in the jail caused the staph infections he contracted. See Van Ort v. Estate of Stanewich, 92 F.3d 831, 837 (9th Cir.1996) (the policy or custom must be the proximate cause of the section 1983 injury).

Section 1983 does not impose liability on a supervisor whose limited involvement did not causally influence an independent, legitimate decision to terminate an employee.

Lakeside-Scott v. Multnomah County · filed 2009-02-12

Accordingly, we hold that, as a matter of law, Fuller’s “wholly independent, legitimate decision to discharge [Scott], uninfluenced by the retaliatory motives of a subordinate” prohibited the jury from finding Brown liable for Scott’s termination.

Section 1983 does not impose liability on a biased subordinate supervisor for a termination when the final decision maker makes a wholly independent, legitimate decision that breaks the causal link to the subordinate’s bias.

Lakeside-Scott v. Multnomah · filed 2009-02-12

On the facts of this case, where the evidence shows “that the final decision-maker made a wholly independent, legitimate decision to discharge the plaintiff, uninfluenced by the retaliatory motives of” Brown, we hold that the neutrality of the decisionmaking process eliminated any “causal” link to Brown’s bias.

Section 1983 requires proof of an affirmative causal connection between a defendant’s acts or omissions and the alleged constitutional deprivation.

Wingster v. Head · filed 2009-03-09

Additionally, “[a] § 1983 claim requires proof of an affirmative causal connection between the defendant’s acts or omissions and the alleged constitutional deprivation.”

Section 1983 requires plaintiffs to show that the defendant's actions caused the alleged constitutional deprivation.

Sullivan v. City of Springfield · filed 2009-03-24

In order to have a valid claim under § 1983, plaintiffs must show that defendant's actions were the cause in fact of the alleged constitutional deprivation.

Section 1983 requires a plaintiff to show a causal link between the alleged constitutional violation and the injury.

Best v. Essex County, New Jersey Hall of Records · filed 1993-02-22

There is no doubt that, even though the appellees may have breached their constitutional duties regarding the custody and care of the detainees at the annex, in order to recover Best must present evidence relating the breach of duty to the assault. We have defined this obligation in actions under 42 U.S.C. § 1983 using such terms as “proximate causation,” “causally related,” “plausible nexus,” and “affirmative link.”

Section 1983 requires a causal connection between the defendant’s conduct and the deprivation of a constitutional right.

Hampton v. Ralph Mouser, Sheriff of Stoddard County, Missouri · filed 1983-03-16

Causation is thus an element of every section 1983 action.

Section 1983 liability for an arrest is cut off by an independent grand jury’s decision unless the plaintiff shows that the defendant tainted its deliberations.

Porter v. Farris · filed 2009-05-01

The rule in this Circuit is that “once facts supporting an arrest are placed before an independent intermediary such as a . . . grand jury, the intermediary’s decision breaks the chain of causation” for a Fourth Amendment claim. ... However, such a claim “may be maintained if the plaintiff affirmatively shows that the deliberations of that intermediary were in some way tainted by the actions of the defendants.” ... Summary judgment on Porter’s § 1983 claim was proper.

A Section 1983 plaintiff must show that the defendant’s unconstitutional conduct actually and proximately caused the claimed injuries.

Browne v. San Francisco Sheriff's Department · filed 2009-05-13

The plaintiff must also show that the defendant’s unconstitutional conduct was the actual and proximate cause of the plaintiffs injuries. ... Plaintiff claims in his responses to interrogatories that he suffers from “PTSD, anxieties, depression, and personality disorder,” but he provides no evidence showing that these alleged injuries were caused by the conduct of Sergeant Freeman or Deputies Fields and Miller on January 22, 2003.

Section 1983 requires a causal link between the defendant’s conduct and the deprivation of the plaintiff’s federal rights.

Utah Animal Rights Coalition v. Salt Lake County · filed 2009-06-01

To prevail on a § 1983 claim, a plaintiff must demonstrate that he was deprived of his federal rights and that the deprivation was caused by a person acting under color of state law. ... We agree that the plaintiffs have failed to show the requisite causal link between the county defendants’ conduct and the disbanding of the protest, and we therefore affirm on those grounds without reaching the color-of-law issue.

Section 1983 requires the defendant to have caused the deprivation of rights; independent intervening decisions can break the causal link.

Taylor v. Brentwood Union Free School District · filed 1998-05-06

Because no reasonable factfinder could conclude that Rooney was the cause of any constitutional harm or injury to Taylor, Taylor cannot prevail in this § 1983 action.

A § 1983 claim against a county requires the county’s conduct to have caused the injury.

Estate of Claude Brooks, by and Through Its Administrator, Clarence "Ed" Brooks v. United States of America, and County · filed 1999-11-18

Causation is, of course, a required element of a § 1983 claim. ... That being so, the element of causation is missing from the § 1983 claim, and dismissal with prejudice was proper.

Section 1983 requires evidence that the defendants’ actions caused the claimed injury to sustain a conditions of confinement claim.

MALLES v. Lehigh County · filed 2009-07-27

To survive summary judgment, Malles must also produce sufficient evidence that defendants’ actions were the proximate cause of his injuries. ... Because the conditions at the Prison, as compared to those in Keller, do not rise to the level of a constitutional violation, and because Malles has presented no evidence of causation, we will dismiss Malles’s § 1983 claim with regard to the conditions of the prison and defendants’ alleged failure to protect him from becoming infected with MRSA.

Section 1983 plaintiffs claiming that officials threatened them to deter protected testimony must prove that the anticipated testimony was a but-for cause of the threats.

Fairley v. Andrews · filed 2009-08-20

Plaintiffs must show that their potential testimony, not their internal complaints, caused the assaults and threats. This means but-for causation.

Section 1983 permits a claim against an officer who coerces a confession when its later use by a prosecutor was reasonably foreseeable.

Stoot v. City of Everett · filed 2009-09-18

Doing so, we conclude that on the present record, a jury could conclude that the use of the allegedly coerced statements against Paul was a reasonably foreseeable consequence of Jensen’s decision to interrogate Paul and file a police report detailing his alleged confession, and that Jensen is therefore an appropriate defendant in this § 1983 suit.

Section 1983 requires a proximate causal link between a defendant’s conduct and the plaintiff’s injury.

Gilmore v. Bostic · filed 2009-09-22

Numerous circuit courts, including the Fourth Circuit, have held that the causal link in § 1983 cases is analogous to common law proximate cause. ... The plaintiff does not allege that the communication between Bostic and the Prison Defendants caused him any injury.

Section 1983 requires a plaintiff to prove that the alleged violation of federal law caused the claimed injury before recovering damages.

Munoz v. City of Philadelphia · filed 2009-09-24

This is because, in general, they must prove that a violation of federal law (i.e., the URA notice requirement) caused their injuries before they can recover from the violator under § 1983.

Section 1983 requires a plaintiff to raise a triable issue that each defendant proximately caused the alleged injury.

Bailey v. D. Cox · filed 2009-12-14

The district court properly granted summary judgment on Bailey’s claims against the remaining defendants because Bailey failed to raise a triable issue as to whether these defendants proximately caused the injury of which Bailey complains.

A Section 1983 plaintiff must identify facts creating a triable issue that a defendant caused a constitutional injury.

Fletcher v. State of Nebraska · filed 2009-12-14

Following our careful de novo review, see McBurney v. Stew Hansen’s Dodge City, Inc., 398 F.3d 998, 1001 (8th Cir. 2005), we conclude that Fletcher did not identify any facts creating a triable issue as whether any defendant caused a constitutional injury in the course of investigating allegations of child abuse.

Section 1983 permits liability when a defendant sets in motion acts by others that the defendant knew or reasonably should have known would cause a constitutional injury.

Sanchez v. Pereira-Castillo · filed 2009-12-23

We have explained that the causal connection alluded to by the statute "can be established not only by some kind of [] personal participation in the deprivation, but also by setting in motion a series of acts by others which the actor knows or reasonably should know would cause others to inflict the constitutional injury." Gutierrez-Rodriguez, 882 F.2d at 561 (quotation marks omitted).

Section 1983 requires a sufficient causal connection between the defendant's actions and the constitutional deprivation.

Burnsworth v. PC Laboratory · filed 2010-01-28

This is not enough to satisfy causation in the § 1983 context — even under a “setting in motion” theory.

In a § 1983 action, causation is normally a question of fact for the jury.

Jackson v. Stevens · filed 2010-02-11

The presence of the requisite causation in a case brought under 42 U.S.C. § 1983 is normally a question of fact for the jury.

Section 1983 requires a plaintiff to plausibly allege a causal connection between the defendant’s conduct and a deprivation of constitutional rights.

Zutz v. Nelson · filed 2010-04-15

These appellees cannot be liable under § 1983 for the Board's action unless the appellants can show a causal connection between the appellees' conduct and the Board's action depriving appellants of a constitutional right.

Section 1983 requires a foreseeable causal connection between a defendant’s conduct and the constitutional injury; supplying a polygraph report for an unrelated investigation did not make the defendants responsible for a later sentencing decision.

Osborn v. Butler · filed 2010-05-11

The foreseeability of the constitutional deprivation is a requisite element. In this case, however, there is no causal connection between the erroneously scored polygraph test undertaken during an investigation of prison violence submitted to the Attorney General’s office, and the discretionary decision of the sentencing judge.

Section 1983 requires plaintiffs to prove that the defendant’s conduct was both a cause in fact and a proximate cause of the harm.

Coscia v. Town of Pembroke, Mass. · filed 2010-06-04

As in any suit under section 1983, the plaintiffs will need to prove that defendants’ conduct was both a cause in fact and proximate cause of the harm (Coscia’s suicide).

Section 1983 liability requires a defendant’s act or legally required omission to cause the alleged deprivation.

McKinney v. Casey · filed 2010-10-05

The district court properly granted summary judgment because McKinney failed to raise a genuine issue of material fact as to whether defendants caused the alleged denial of exercise. See Leer v. Murphy, 844 F.2d 628, 633 (9th Cir. 1988) (an official is liable under section 1983 only “if he does an affirmative act, participates in another’s affirmative acts, or omits to perform an act which he is legally required to do that causes the deprivation” of which plaintiff complains) (citation and internal quotation marks omitted).

Section 1983 can impose liability on officials who set in motion events they knew or reasonably should have known would cause others to violate a plaintiff’s constitutional rights.

Dantrassy v. Kay County Board of County Commissioners · filed 2010-10-13

Appellants may be found liable “‘if [they] set in motion a series of events that [they] knew or reasonably should have known would cause others to deprive the plaintiff of [his] constitutional rights.’” Buck v. City of Albuquerque, 549 F.3d 1269, 1279-80 (10th Cir. 2008) (quoting Snell v. Tunnell, 920 F.2d 673, 700 (10th Cir. 1990) (further quotation omitted)). ... The facts summarized by the district court, including evidence showing that appellants failed to correct deficiencies at the jail but, instead, relied on inmate “pod bosses” to maintain order, clearly fall within the standard for causation established in Tenth Circuit law.

A defendant may be liable under § 1983 for causing a constitutional deprivation even when a supervisor makes the final decision.

Anthony v. Stepp · filed 2010-10-29

The evidence that defendants’ falsified a misconduct report and that the facts in this report caused their supervisor to place Anthony in segregation, construed in the light most favorable to Anthony, raised a triable issue that defendants might be liable for causing Anthony’s confinement in segregation.

Section 1983 allows a claim against an investigator whose conduct causes a constitutional deprivation, even if the investigator does not personally make the decision to deprive the plaintiff of a right.

Jones v. State, Dept. of Health · filed 2010-11-04

As long as a sufficient causal connection is established between the defendant official's conduct and the violation, a § 1983 plaintiff does not have to prove that the defendant official personally violated the plaintiff's right.

Section 1983 requires a causal connection between a defendant’s actions and the harm for which the plaintiff seeks relief.

Oldfield v. Village of Dansville · filed 2011-01-18

Thus, plaintiffs’ claims against the County fail because of the lack of any causal nexus between the County’s actions and any harm allegedly suffered by plaintiffs.

Section 1983 requires a plaintiff to show that the defendant was both the but-for and proximate cause of the injury.

Calvert v. Ediger · filed 2011-03-04

To prevail on a claim brought pursuant to § 1983, a plaintiff must demonstrate the defendant was both the but-for and proximate cause of the plaintiff’s injury.

Section 1983 requires a plaintiff to establish both causation in fact and proximate causation.

Lamont v. New Jersey · filed 2011-03-04

Like a tort plaintiff, a § 1983 plaintiff must establish both causation in fact and proximate causation.

Section 1983 requires a plaintiff to show that the defendant caused the constitutional deprivation; speculation does not establish that causal connection.

Harris v. Matthews · filed 2011-03-28

That is clearly insufficient to establish Matthews’ actions in November 2008 caused the August 2009 assault.

Section 1983 can impose liability on an officer whose false report foreseeably causes others to deprive a prisoner of necessary medical care.

Jaundoo v. Clarke · filed 2011-03-28

The record before this court shows there are material facts in dispute that, if resolved in Jaundoo’s favor, would allow a reasonable jury to find that Kearnan’s transmission of the presumably false report to Fisher “set[ ] in motion a series of acts by others which [Kearnan knew] or reasonably should [have] know[n] would cause others to inflict the constitutional injury” and that Kearnan acted with the intent to punish Jaundoo.

Section 1983 requires proximate causation for damages, and an independent, unforeseeable assault can break the causal chain.

Martin v. City of New York · filed 2011-06-24

Actions brought under § 1983 are similar to tort actions since they both serve to compensate victims, and “[a] § 1983 action, like its state tort analogies], employs the principle of proximate causation.” ... Catty’s own culpability, manifestly, supersedes that of defendants, foreclosing a finding of proximate causation.

Section 1983 requires a plaintiff to show an affirmative causal connection between a particular person acting under color of state law and the constitutional deprivation.

Allen v. Zavaras · filed 2011-07-18

In addition, to establish liability of a prison official under § 1983, the inmate must prove “an affirmative causal connection between the actions taken by a particular person ‘under color of state law’ and the constitutional deprivation.”

Section 1983 requires a damages plaintiff to allege that the defendant’s conduct caused the injuries in fact and proximately.

Paramount Contractors & Developers, Inc. v. City of Los Angeles · filed 2011-08-02

To state a 42 U.S.C. § 1983 claim for damages, a plaintiff must allege that the defendant’s conduct was the actionable cause of its injuries, which includes allegations of both causation-in-fact and proximate causation. See Tahoe-Sierra Pres. Council, Inc. v. Tahoe Reg’l Planning Agency, 216 F.3d 764, 783 (9th Cir.2000), aff 'd 535 U.S. 302, 122 S.Ct. 1465, 152 L.Ed.2d 517 (2002). A claim fails when there are “intervening causes that break the chain of proximate causation.” Van Ort v. Estate of Stanewich, 92 F.3d 831, 837 (9th Cir.1996).

Section 1983 requires proximate causation, but the defendant’s conduct need only be a cause of harm rather than the sole cause.

Drumgold v. Callahan · filed 2011-08-24

In the final analysis, § 1983 is governed by tort law and is best understood “against the background of tort liability that makes a man responsible for the natural consequences of his actions.” ... As in tort, however, to constitute proximate cause of a harm under § 1983, the conduct must be a cause but it need not be the only cause. ... Upon this review, therefore, I conclude that the jury instructions on causation were not in error. The jury was appropriately instructed that to constitute proximate cause, Drumgold’s conviction had to be a reasonably foreseeable result of Callahan’s conduct, and that Callahan’s conduct was reasonably likely to have caused harm even if it had not been acting in concert with other forces.

A Section 1983 plaintiff bears the burden of proving that the defendants proximately caused a violation of the plaintiff’s constitutional rights.

Gates v. District of Columbia · filed 2011-11-18

In Counts 2 through 5, Gates asserts section 1983 claims with respect to which he bears the burden to prove that defendants proximately caused a violation of his constitutional rights.

Section 1983 requires causation as an element of liability.

Andreyev v. Kjorlie · filed 2011-11-30

Causation is an element of § 1983, which creates a species of tort liability.

Section 1983 requires a plaintiff to show that the defendants caused the alleged deprivation of constitutional rights.

Armentero v. Levan · filed 2012-01-11

The district court properly granted summary judgment because Armentero failed to raise a genuine dispute of material fact as to whether defendants caused the alleged deprivation of his constitutional rights based on his racial classification.

Section 1983 requires evidence linking a particular defendant to the alleged constitutional violation.

Farkarlun v. Hanning · filed 2012-03-02

Section 1983, however, requires more than merely establishing a constitutional violation occurred. In particular, § 1983 requires evidence of causation. Causation requires evidence linking a particular defendant to the acts alleged to be a constitutional violation.

Section 1983 requires a plaintiff to establish a causal connection between each defendant’s acts or omissions and the injury suffered.

Hafez v. City of Schenectady · filed 2012-04-19

As such, for a plaintiff to recover in a section 1983 action, he must establish a causal connection between the acts or omissions of each defendant and any injury or damages he suffered as a result of those acts or omissions.

Section 1983 requires causation between the constitutional violation and the injury as part of liability for compensatory damages.

Singletary v. District of Columbia · filed 2012-07-17

What the District is talking about is causation, and causation goes to liability, and not damages. ... But whether an injury is compensable at all is a liability issue. ... The opinion does not stand for the proposition that the causation question must be presented to the jury as part of the damages case.

Section 1983 requires a causal link between the defendant’s conduct and the plaintiff’s injury.

Dickerson v. Prison Health Services Inc. · filed 2012-09-07

Insofar as plaintiff spoke to Officer Farley only after the sexual misconduct at issue had already occurred, there is plainly no causal link between that injury and Officer Farley’s now-challenged advice.

Section 1983 allows liability for officers who coerce a false confession that later causes harm through its use in court, even if the officers do not testify.

Hobbs v. Cappelluti · filed 2012-09-28

The act of coercing a false confession from Hobbs could be the "but-for” and "proximate cause” of the harm resulting from the in-court use of his confession regardless of whether defendant officers testified against him.

Section 1983 requires a plaintiff to plausibly plead that the defendant caused the alleged constitutional violation.

Tringali v. Mass Dept of Transit. Asst. · filed 2012-11-13

I apply "common law tort principles when conducting 'inquiries into causation under § 1983.'"

Section 1983 requires a plaintiff seeking damages for withheld exculpatory evidence to prove by a preponderance of the evidence that the withholding caused the conviction under a but-for standard.

Drumgold v. Callahan · filed 2013-01-31

Once a Brady violation has been shown, the causation inquiry in a § 1983 damages suit is only a "but for" inquiry pursuant to the preponderance of the evidence standard.

Section 1983 requires a plaintiff to allege facts showing that the defendant’s conduct caused an injury or deprivation of a protected interest.

Tolbert v. LeBlanc · filed 2013-02-15

Thus, while Tolbert argues to excess about the entirely uncontested fact that his sentence was temporarily miscalculated, he fails to allege any fact that would establish that the error caused him any injury or deprivation of a protected liberty interest. See Murray v. Earle, 405 F. 3d 278, 290 (5th Cir. 2005) (noting that § 1983 requires a showing of proximate causation); Baldwin v. Daniels, 250 F.3d 943, 946 (5th Cir. 2001) (noting that a plaintiff must show that the defendant’s action resulted in a deprivation of a protected interest).

Section 1983 requires the defendant’s actions to be both a but-for cause and a proximate cause of the claimed injury.

James Ex Rel. Murphy v. Chavez Ex Rel. Mayor of Albuquerque · filed 2013-02-19

In order to prevail on her § 1983 claims against Officer Carter, appellant is required to show that Officer Carter’s actions, namely, shooting at Mr. Murphy and ordering the SWAT team into the house, were both the but-for and the proximate cause of Mr. Murphy’s death.

A § 1983 claim requires a causal link between the defendant’s conduct and the constitutional deprivation; an independent judicial decision can break that link.

Manzini v. The Florida Bar · filed 2013-03-11

The decision of that state court judge breaks the chain of causation between Moore’s actions and any alleged constitutional violations.

Section 1983 requires causation between the defendant’s conduct and the alleged injury.

Smith v. Buss · filed 2013-06-21

Causation is an element of a claim under § 1983, ... and no jury reasonably could find on this record that the urine incident and Smith’s later assault on Hunter were anything but unrelated events.

Section 1983 requires a plaintiff to prove that the defendants’ conduct caused the claimed injury; complex medical causation may require expert evidence.

Maraj v. Massachusetts · filed 2013-07-17

It is Plaintiffs burden to prove that Defendants’ conduct caused Leslie’s death. Expert evidence of causation is necessary in light of (1) the complexity of causation in this case, (2) Leslie’s pre-existing heart condition, and (3) the Medical Examiner’s findings. ... Plaintiff does not dispute that causation is an essential element of its § 1983 claim, or that expert evidence is necessary to prove causation.

Section 1983 requires evidence that a defendant caused the deprivation of constitutional rights.

Drake v. Village of Johnstown, Ohio · filed 2013-08-16

The question then becomes whether Drake presented sufficient evidence that a Defendant other than Berryhill “cause[d] the plaintiff to be subjected to deprivation of his constitutional rights,” as § 1983 requires. Baker v. McCollan, 443 U.S. 137, 142 (1979). We conclude that he did not.

Section 1983 causation can be tried when evidence could show that a defendant’s actions contributed to a constitutional injury, even if others committed the final act.

Barry Hazle, Jr. v. Crofoot · filed 2013-08-23

We hold that, when the facts are taken in the light most favorable to Hazle, a genuine issue of material fact exists as to whether Westcare’s actions causally contributed to the violation of Hazle’s constitutional rights. We thus reverse the grant of summary judgment in Westcare’s favor with regard to Hazle’s section 1983 claim.

A § 1983 plaintiff must show that the defendant’s misconduct was both the proximate and but-for cause of the injury.

Arnold v. Geary · filed 2013-11-07

For any claim brought under 42 U.S.C. § 1983, the plaintiff must establish that the defendant’s misconduct was the proximate cause of the plaintiffs injury. ... In addition, the plaintiff must show that the defendant’s misconduct was the “but for” cause or cause “in fact” of the injury.

Section 1983 requires a plaintiff to show an injury causally linked to the challenged conditions of confinement.

Schell v. Jones · filed 2013-12-16

Because § 1983 requires him to demonstrate an injury that is causally linked to his conditions of confinement, this is fatal to his claim.

Section 1983 requires plaintiffs to prove that the defendant caused their alleged injuries.

Marcus Gerlach Susan Gerlach v. City of Bainbridge Island · filed 2014-01-06

Section 1983 requires plaintiffs to prove causation.

Section 1983 requires a causal connection between each defendant’s acts or omissions and the plaintiff’s injury or damages.

Wandering Dago Inc. v. New York State Office of General Services · filed 2014-01-15

As such, for a plaintiff to recover in a section 1983 action, he must establish a causal connection between the acts or omissions of each defendant and any injury or damages he suffered as a result of those acts or omissions.

Section 1983 requires facts linking each defendant to an alleged adverse action.

Gray v. Shedd · filed 2014-02-28

The district court properly dismissed Gray’s retaliation claims as to ... defendants Clausen, Hammer, Johnson, King, Nicodemus, Olesen, Roane, Titsworth, and Watts because Gray failed to allege sufficient facts to show retaliatory intent or link these defendants to an alleged adverse action.

Section 1983 requires a plaintiff to allege facts linking defendants to the adverse action for which they are sued.

Coleman v. Maldonado · filed 2014-03-19

Dismissal of Coleman’s action was proper because Coleman failed to allege facts in his fifth amended complaint sufficient to show retaliatory intent or to link defendants to the alleged adverse action.

Section 1983 requires a plaintiff to show an affirmative causal connection between the defendant’s conduct and the alleged constitutional deprivation.

Johnson v. Razdan · filed 2014-04-30

To prevail in a § 1983 civil rights action, a plaintiff must prove an affirmative causal connection between the defendant’s acts or omissions and the alleged constitutional deprivation.

Section 1983 makes a defendant liable for foreseeable acts by others that cause a constitutional injury when the defendant sets those acts in motion.

Tatum v. Moody · filed 2014-09-17

Thus, a § 1983 defendant is liable for “setting in motion a series of acts by others which the actor knows or reasonably should know would cause others to inflict the constitutional injury.” Crowe v. Cnty. of San Diego, 608 F.3d 406, 430 (9th Cir. 2010) (internal quotation marks omitted). Here, “the natural consequence[]” of Moody and Pulido’s conduct was that Walker remained in detention until the exculpatory information was disclosed to the prosecutors and then to Walker’s lawyers.

Section 1983 requires a plaintiff to show that the defendant’s misconduct was both a but-for cause and a proximate cause of the injury.

Arnold v. Geary · filed 2014-11-04

A Section 1983 plaintiff must also demonstrate that the defendant’s alleged misconduct was both the “but for” cause and the proximate cause of his injury.

Section 1983 requires a plaintiff to show that each defendant’s conduct caused the claimed injury.

Hamilton v. S. White · filed 2014-12-05

The district court properly granted summary judgment on Hamilton’s excessive force claim against defendants Milson, Morelli and Thomas. Those defendants did not use force against Hamilton, and Hamilton has presented no facts from which it can reasonably be inferred that they caused or should have foreseen the use of pepper spray on Hamilton.

Section 1983 requires evidence connecting the defendant to the conduct alleged to have caused the injury.

Bertram v. Sizelove · filed 2014-12-12

The district court properly granted summary judgment because Bertram failed to raise a genuine dispute of material fact as to whether defendant Sizelove was deliberately indifferent to Bertram’s safety or was responsible for assigning Bertram to an upper bunk.

Section 1983 requires a causal connection between a defendant and the alleged constitutional violation.

Koerner v. Cox · filed 2014-12-18

The district court properly granted summary judgment for Cox and Del Porto because Koerner failed to raise a genuine dispute of material fact as to whether these defendants were the cause of any constitutional violations.

Section 1983 permits liability when a defendant sets in motion acts by others that the defendant knows or reasonably should know will cause a constitutional injury.

Rice v. Murakami · filed 2014-12-18

Thus, a § 1983 defendant is liable for “setting in motion a series of acts by others which the actor knows or reasonably should know would cause others to inflict the constitutional injury.” ... Because there are questions of fact over whether Officer Murakami’s Code 3 alarm set in motion a series of events that she should have known would result in excessive force being used against Rice, the Court will deny her motion for summary judgment on this issue.

Section 1983 damages require proof that the constitutional violation proximately caused the claimed injury.

Kane v. Lewis · filed 2015-03-13

A plaintiff asserting a constitutional tort under § 1983 must therefore satisfy the familiar element of proximate causation.

Section 1983 can impose liability on a state actor for a third party’s constitutional violation when the state actor proximately caused it.

A.M. ex rel. Youngers v. New Mexico Department of Health · filed 2015-05-15

Section 1983 attaches liability for a state actor who “subjects, or causes to be subjected, any citizen ... to the deprivation of any rights, privileges or immunities secured by the Constitution.” 42 U.S.C. § 1983. That language means that the Individual DOH Defendants can be held liable for third parties’ acts that they did not personally commit, such as M. Evans’ subjecting A.M. to involuntary servitude.

A § 1983 false imprisonment plaintiff must show that the defendant tainted the deliberations of judicial or grand jury intermediaries who found probable cause.

Allen v. Jackson County Ex Rel. Board of Supervisors · filed 2015-08-19

Because, a judge issued an arrest warrant, a grand jury returned an indictment, and after a habeas corpus hearing, a second judge found “sufficient probable cause” supporting his arrest, Dr. Allen rightly concedes he must show that the deliberations of these intermediaries “‘were in some way tainted by the actions of the defendant.’”

Section 1983 requires a causal connection between the defendant’s conduct and the alleged injury.

Thomas v. Rw Stevwing, Jr. · filed 2015-09-04

The district court properly granted summary judgment on Thomas’s retaliation claim against Stevwing because Thomas failed to raise a genuine dispute of material fact as to whether Stevwing was responsible for the termination of Thomas’s prison job or transfer to another unit.

Section 1983 requires facts showing a causal connection between an official’s acts or omissions and the alleged constitutional deprivation.

Derrick L. Gibson, Sr. v. Doe · filed 2015-10-22

Gibson must also allege facts demonstrating “an affirmative causal connection between the official’s acts or omissions and the alleged constitutional deprivation.” See Zatler v. Wainwright, 802 F.2d 397, 401 (11th Cir. 1986). ... Gibson has also alleged no facts demonstrating a causal connection between the Records Custodian’s alleged acts and delay in Gibson’s obtaining relief.

Section 1983 requires causation to be assessed individually based on each defendant's duties and responsibilities.

Patten v. Stone · filed 2015-12-01

The district court properly granted summary judgment to defendant Upshaw because Patten failed to raise a genuine dispute of material fact as to whether Upshaw’s alleged misconduct proximately caused any harm to Patten. See Leer v. Murphy, 844 F.2d 628, 633 (9th Cir. 1988) (the causation analysis under § 1983 is “individualized and focus[es] on the duties and responsibilities of each individual ... defendant whose acts or omissions are alleged to have caused a constitutional deprivation”).

Section 1983 limits liability to consequences of a defendant’s actions that are natural and reasonably foreseeable.

Walker v. City of New York · filed 2016-01-05

Section 1983 defendants can be held to answer only for the “natural,” “reasonably foreseeable” consequences of their actions, Warner v. Orange Cty. Dep’t of Prob., 115 F.3d 1068, 1071 (2d Cir. 1996) (internal quotation marks omitted), and at the time Hennin arrested Walker he could not have foreseen that Walker’s arraignment would be delayed by a stationhouse assault and a ten-hour trip to the hospital.

Section 1983 requires allegations that the challenged conduct caused the plaintiff’s claimed damages.

Bowen v. Nassau County · filed 2016-01-20

In any event, the plaintiff’s allegations failed to show that the officers’ challenged conduct caused his claimed damages.

Section 1983 permits liability for an officer whose conduct causes a constitutional deprivation when a foreseeable intervening act does not break the causal chain.

Pauly Ex Rel. Estate of Pauly v. White · filed 2016-02-09

In other words, Officers Mariscal and Truesdale may be held liable if their conduct immediately preceding the shooting was the but-for cause of Samuel Pauly’s death, and if Samuel Pauly’s act of pointing a gun at the officers was not an intervening act that superseded the officers’ liability.

Section 1983 requires the state actor’s conduct to proximately cause the plaintiff’s harm; an independent judicial error breaks that causal chain unless the actor deceived the judge.

Johnson v. Provenzano · filed 2016-04-14

A § 1983 claim requires that the state actor was the proximate cause of the plaintiff’s harm. ... Thus, if any obligation has gone unfulfilled regarding service, it is that of the court, and such a judicial act precludes Officer Provenzano’s liability (under either due process or the Fourth Amendment).

Section 1983 requires the defendant’s conduct to cause the constitutional violation; a prosecutor’s independent charging decision can break that chain of causation.

Hackenmueller v. Fadden · filed 2016-07-22

Causation issues under § 1983 are analyzed under the common law. ... Under the circumstances, the Court concludes there is no genuine issue that the City Attorney’s charging decision broke the chain of causation, regardless of whether Fadden intentionally falsified information in his report.

Section 1983 requires a plaintiff to show that the defendant caused a constitutional violation.

Keith Arline, Jr. v. Gower · filed 2016-08-03

The district court properly granted summary judgment for defendant Speers because Arline failed to raise a genuine dispute of fact as to whether Speers caused any constitutional violation. See Preschooler II v. Clark Cty. Sch. Bd. of Trs., 479 F.3d 1175, 1183 (9th Cir. 2007) (discussing causation under § 1983).

Section 1983 does not impose liability on a prosecutor for an extended detention caused by unconstitutional search procedures that the prosecutor neither directed nor could reasonably foresee.

Eckert v. Dougherty · filed 2016-09-14

But Mr. Dougherty cannot be liable for that extended detention because (1) Mr. Eckert conceded that he “does not and cannot allege that Dougherty directed the officers to conduct an unlawful search,” Aplt. App. at 112, and (2) as the district court held, it was not reasonably foreseeable to Mr. Dougherty that Mr. Eckert would be subjected to unconstitutional procedures (and the concomitant delay) after the initial negative test results.

A person who submits a false incident report that causes a prison disciplinary proceeding cannot avoid § 1983 liability merely because others conduct the proceeding.

Stetzel v. Holubek · filed 2016-09-15

Holubek does not dispute that the only basis for Stetzel’s disciplinary proceeding was the incident report that she prepared. As in Pierce, she cannot “hide behind” the actions of others who were also involved in the proceedings.

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Carter v. Nick Dawson · filed 2016-11-03

The district court properly granted summary judgment because Carter failed to raise a genuine dispute of fact as to whether defendants caused Carter to contract a bacterial infection.

Section 1983 permits liability when a state actor initiates actions it knew or reasonably should have known would cause others to deprive someone of a right.

Vogt v. City of Hays · filed 2017-01-04

Thus, causation exists if Hays initiated actions that it knew or reasonably should have known would cause others to deprive Mr. Vogt of his right against self-incrimination.

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Dixon v. Legrand · filed 2017-03-01

Summary judgment on Dixon’s access-to-courts claim was proper because Dixon failed to raise a genuine dispute of material fact as to whether defendants’ alleged refusal to request Dixon’s legal materials from Ohio in a timely manner caused his injury. See Lewis v. Casey, 518 U.S. 343, 348-49 (1996) (access-to- courts claim requires actual prejudice to contemplated or existing litigation, such as inability to meet a filing deadline or to present a claim); see also Harper v. City of Los Angeles, 533 F.3d 1010, 1026 (9th Cir. 2008) (“In a § 1983 action, the plaintiff must . . . demonstrate that the defendant’s conduct was the actionable cause of the claimed injury.”).

Section 1983 liability requires a causal link between the defendant’s conduct and the plaintiff’s injury; an informed, neutral court’s decision can break that link.

Smith v. Liddell · filed 2017-03-17

And the school officials cannot be liable under 42 U.S.C. § 1983 because the dependency court—“an informed, neutral decision-maker”—broke the chain of causation between defendants’ reports and Smith’s injury.

Section 1983 provides a remedy for constitutional deprivations caused by a person acting under color of state law, and liability requires a causal link between the person's act and the deprivation.

Avila v. District of Columbia · filed 2017-03-30

Defendant argues that he did not have legal authority to control the duration of the seizure, but whether he had such unilateral authority is not the appropriate inquiry under section 1983. ... The fact that the USAO would have had to sign the form before the van could be released does not break the causal chain making Defendant responsible for the ongoing seizure. Had Defendant sent the form to the USAO and the USAO refused to sign it, the causal link would be broken and Defendant would not be liable under section 1983.

Section 1983 requires a plaintiff seeking damages to prove that the constitutional violation was both a factual and a proximate cause of the injury.

Furber v. Taylor · filed 2017-04-20

Mr. Furber must therefore prove that defendants’ constitutional violations were both the cause-in-fact and the proximate cause of Ms. Furber’s injuries.

Section 1983 requires a plaintiff to allege facts showing that the defendant caused the claimed constitutional deprivation.

Rodriguez v. Isaac · filed 2017-04-25

The district court properly dismissed Rodriguez’s action because Rodriguez failed to allege facts sufficient to show that defendant caused the alleged constitutional deprivation.

A § 1983 deliberate-fabrication claim requires proof that the fabricated evidence caused the plaintiff’s deprivation of liberty.

Spencer v. Krause · filed 2017-05-18

To prevail on a § 1983 claim of deliberate fabrication, a plaintiff must prove that (1) the defendant official deliberately fabricated evidence and (2) the deliberate fabrication caused the plaintiff’s deprivation of liberty.

Causation in a § 1983 retaliation claim is analyzed the same way as causation under Title VII.

Savoy v. Bishop · filed 2017-08-28

The analysis for causation pursuant to § 1983 is the same as it is for Title VII.

Section 1983 does not require a defendant to be the sole cause of a constitutional deprivation.

Carrero v. Farrelly · filed 2017-09-20

Section 1983 provides a cause of action to a person deprived of her constitutional rights against any person who “subjects, or causes [her] to be subjected” to such deprivation. ... A defendant need not be the sole cause of the harm suffered by the plaintiff.

Section 1983 requires state action to cause the alleged injury; a claim fails when state action was not even a but-for cause.

Thomas v. Nationwide Children's Hosp. · filed 2018-02-14

When state action is not even a but-for cause, let alone a proximate cause, of an injury, a § 1983 claim necessarily fails as a matter of law.

Section 1983 requires evidence that the defendant caused the plaintiff’s injury.

Brown v. Felten · filed 2018-05-07

Moreover, under § 1983 Brown must provide evidence that Felten caused an injury.

Section 1983 requires proof of an affirmative causal connection between a defendant’s actions under color of state law and a constitutional deprivation.

Block v. Pohling · filed 2018-05-08

Section 1983 “requires proof of an affirmative causal connection between the actions taken by a particular person under color of state law and the constitutional deprivation.”

A § 1983 plaintiff alleging deliberate fabrication can rebut the presumption of prosecutorial independence by showing that officers gave false evidence to the prosecutor or withheld crucial information.

Caldwell v. City & County of San Francisco · filed 2018-05-11

In sum, if a plaintiff establishes that officers either presented ... false evidence to or withheld crucial information from the prosecutor, the plaintiff overcomes the presumption of prosecutorial independence and the analysis reverts back to a normal causation question.

Section 1983 requires a defendant’s conduct to cause the alleged deprivation of a constitutional right.

Tidwell v. Gallagher · filed 2018-05-22

The district court properly granted summary judgment because Tidwell failed to raise a genuine dispute of material fact as to whether Gallagher caused the delay in providing medical records to an outside specialist.

Section 1983 requires a defendant’s conduct to cause the plaintiff’s injury for the plaintiff to recover.

Juarez v. Walter · filed 2018-05-31

Section 1983 is a species of tort liability. Manuel v. City of Joliet, 137 S. Ct. 911, 916 (2017). This means that Juarez cannot recover if Walter’s silence about Gabapentin’s side effects did not cause his injury.

Section 1983 claims require evidence of causation to survive summary judgment.

Paredes v. Cook County · filed 2018-10-12

Both section 1983 and the Illinois wrongful death statute require evidence of causation to survive summary judgment.

Section 1983 requires plaintiffs to identify the policies or practices causing a constitutional violation and show a direct causal link, while allowing courts to consider how those policies or practices interact.

M. D. Ex Rel. Stukenberg v. Abbott · filed 2018-10-18

In sum, the § 1983 causation component requires that the plaintiffs identify, with particularity, the policies or practices they allege cause the constitutional violation, and demonstrate a “direct causal link.” See Piotrowski, 237 F.3d at 580. We do not, however, read our precedent to require the court to consider each policy or practice in a vacuum. The court may properly consider how individual policies or practices interact with one another within the larger system.

Causation in a § 1983 retaliation claim is analyzed the same way as causation under Title VII.

Gregg-El v. Doe · filed 2019-01-03

We have recognized that the analysis for causation is identical under § 1983 and Title VII of the Civil Rights Act of 1964, as amended.

Section 1983 does not allow a plaintiff to combine uncoordinated officers’ separate uses of force to establish causation against one officer.

Zartner v. Miller · filed 2019-01-09

But when the officers did not coordinate, we have considered each officer’s liability based solely on his or her own acts. ... We therefore conclude that Mr. Zartner failed to show causation through a theory of aggregation.

Section 1983 requires an excessive-force plaintiff to prove a causal connection between each defendant’s actions and the constitutional deprivation.

Peterson v. Smith · filed 2019-02-13

Additionally, to hold a defendant liable for excessive force, a plaintiff must prove causation. ... This causal element is what the jury instruction and verdict forms relay.

Section 1983 requires a plaintiff to prove that the defendant’s conduct caused the alleged injury.

Wright v. Lassiter · filed 2019-04-17

We have expressly held that § 1983 incorporates a causation requirement.

Section 1983 requires an affirmative causal connection between a state actor’s conduct and the constitutional deprivation; allegations that a warden’s comments caused attacks by other inmates can satisfy that requirement at screening.

Harris v. Allen · filed 2019-05-03

Finally, § 1983 “requires proof of an affirmative causal connection between the actions taken by a particular person under color of state law and the constitutional deprivation.” ... Plaintiff’s allegations, though bare-boned, are enough to satisfy the causation element for the purposes of this review.

Section 1983 requires a defendant to cause the alleged deprivation of rights; recommending a protest zone without authority to impose it does not establish liability.

Hartman v. Thompson · filed 2019-07-23

As for Thompson, § 1983 requires that the defendant “subjects, or causes to be subjected” a United States citizen to the deprivation of a constitutional right. 42 U.S.C. § 1983. Thompson did not “cause” the protest zone to occur. He recommended its placement in response to a request from the Fairgrounds’ Board. At bottom, Thompson did not have the legal authority to make the decision to put Plaintiffs in the protest zone.

Section 1983 requires a defendant to subject a person to a deprivation of rights or cause that deprivation; knowledge of a third party’s conduct alone is insufficient.

Altheide v. Kleuczar · filed 2019-07-29

Moreover, the language of 42 U.S.C. § 1983 itself states that a person is liable if he “subjects, or causes to be subjected” a person to the deprivation of a constitutional right. Viewing the facts in the light most favorable to Plaintiff, Plaintiff only can show that Defendants knew about the vendor’s practice of charging the taxes and, for a period of time, erroneously believed the practice to be correct. Plaintiff cannot show that Defendants either subjected him to a deprivation of his tax money or caused him to be subjected to a deprivation of his tax money or that he did not have an adequate post-deprivation remedy.

Section 1983 requires a causal link between the defendant’s conduct and the claimed injury; intervening decisions to use and admit evidence can break that link.

Lewis v. Mills · filed 2019-08-16

Moreover, even assuming that Plaintiff's statements were taken in violation of the Fifth Amendment, the prosecutor's decision to use that evidence, and the trial judge's decision to deny Plaintiff's motion to suppress, were intervening factors, precluding a finding that Defendant Golden's actions caused the evidence to be used against Plaintiff.

Section 1983 requires an affirmative causal connection between an official’s acts or omissions and the alleged constitutional deprivation.

Jones v. Rodgers · filed 2019-08-23

Section 1983 “requires proof of an affirmative causal connection between the official's acts or omissions and the alleged constitutional deprivation.” ... Based on Amended Complaint’s allegations, the Court concludes that Plaintiff has stated a claim of retaliation that is plausible on its face.

Section 1983 requires proof that the defendant caused the alleged deprivation of a federal right.

Hatfield v. Gmoser · filed 2019-09-06

To prevail on a claim under 42 U.S.C. § 1983, a plaintiff must prove two elements: (1) the plaintiff was deprived of a right secured by the Constitution or laws of the United States; and (2) that the deprivation was caused by a person acting under color of law. ... There is no evidence that Defendant was responsible for reassigning Plaintiff.

Section 1983 requires a causal connection between each defendant’s acts or omissions and the plaintiff’s injury.

Champion v. Kirkpatrick · filed 2019-09-17

As such, for a plaintiff to recover in a Section 1983 action, he must establish a causal connection between the acts or omissions of each defendant and any injury or damages he suffered as a result of those acts or omissions. ... The Court finds that these allegations sufficiently allege a causal connection between the acts of Defendant Labare and Plaintiff's injuries, thereby presenting claims that are plausible on their face.

Section 1983 requires a plaintiff to establish that the defendant’s conduct was both the cause-in-fact and proximate cause of the claimed injury.

Coleman v. Figueroa · filed 2019-09-26

The district court properly granted summary judgment because Coleman failed to raise a genuine dispute of material fact as to whether defendant Figueroa caused Coleman’s injury. See Harper v. City of Los Angeles, 533 F.3d 1010, 1026 (9th Cir. 2008) (in order to sustain a § 1983 claim, the plaintiff must establish that the defendant’s conduct was the cause-in-fact and proximate cause of the claimed injury).

Section 1983 requires an official’s conduct to cause the adverse employment action before the official can be held liable.

Beattie v. Madison County School District · filed 2001-07-05

If Acton and Jones did not ... cause the adverse employment action, they ... cannot be liable under § 1983, no matter how ... unconstitutional their motives.

Section 1983 requires a causal link between the defendant’s conduct and the alleged constitutional deprivation.

Munoz v. California Department of Corrections and Rehabilitation · filed 2019-10-09

Even if the Court infers from Plaintiff’s medical expert’s report that, in the expert’s opinion, Defendant should have interviewed and physically examined Plaintiff immediately prior to reviewing Plaintiff’s chrono, ECF No. 61-2 at PX5, Plaintiff has not established a clear linkage between that failure, his ultimate injury, and a constitutional deprivation, as required by a claim under § 1983.

Section 1983 requires a causal link between a defendant’s conduct and the plaintiff’s injury; independent decisions by intervening officials can break that link.

Carruth v. Bentley · filed 2019-11-07

The requisite “causal relation” for a § 1983 claim “does not exist when the continuum between Defendant’s action and the ultimate harm is occupied by the conduct of deliberative and autonomous decision-makers.” Dixon, 303 F.3d at 1275. ... Under a straightforward application of Dixon, then, there were “intervening free, independent, and volitional acts” between any improper acts by the defendants and the decisions taken by Administrator Moore and the members of the Board of Directors of the ACUA that caused Carruth’s injuries.

Section 1983 requires a plaintiff to show that a defendant acting under color of state law caused the alleged deprivation of a federal right.

(PC) Mosley v. Cargill · filed 2019-12-09

A Section 1983 plaintiff must show that a defendant acting under color of state law caused an alleged deprivation of a right secured by federal law.

A plaintiff seeking damages under § 1983 must allege that the defendants caused the plaintiff’s injury.

STERLING v. LONG · filed 2019-12-09

But, as discussed above, to state a claim for damages under 42 U.S.C. § 1983, a plaintiff must allege that the defendants caused his injury.

Section 1983 requires a plaintiff to plead a causal link between the defendant’s conduct and the alleged deprivation of federal rights.

Nelson v. Doty · filed 2019-12-11

Importantly in a § 1983 action, a plaintiff must demonstrate causation, or show how the defendant, acting under color of state law, allegedly violated the plaintiff’s federal rights. ... However, Mr. Nelson has not plausibly alleged a violation of either the U.S. Constitution or a federal statute, or that Defendant Axelsson caused an injury to his rights.

Section 1983 requires a plaintiff to show a plausible causal link between the defendant’s conduct and the injury; expert testimony is not always necessary to establish that link.

WARREN v. PRIME CARE MEDICAL INC. · filed 2019-12-20

Thus, Warren has produced sufficient evidence of proximate causation to survive summary judgment without expert testimony.

Section 1983 requires a causal connection between a defendant’s acts and the alleged constitutional violation.

Burnett v. DeSoto County Jail · filed 2020-01-06

For a plaintiff to state a valid claim under § 1983, he must “identify defendants … whose acts are causally connected to the constitutional violation alleged.” Woods v. Edwards, 51 F.3d 577, 583 (5th Cir. 1995) (citing Lozano v. Smith, 718 F.2d 756, 768 (5th Cir. 1983)).

Section 1983 requires a plaintiff to prove both causation in fact and proximate causation.

Bearchild v. Cobban · filed 2020-01-16

We start from first principles: “[i]n a § 1983 action, the plaintiff must . . . demonstrate that the defendant’s conduct was the actionable cause of the claimed injury. To meet this causation requirement, the plaintiff must establish both causation-in-fact and proximate causation.”

An individual can be liable under § 1983 for a board’s decision without voting on the board if the individual caused its decision.

Naini v. King County Hospital District No 2 · filed 2020-01-21

Contrary to Defendants’ assertion, (see Dkt. No. 80 at 16–17), these causation principles do not require that a person be a voting member of a board for the person to be liable for the board’s decision. Such a requirement would contradict the plethora of cases holding that a subordinate government employee is liable under § 1983 for the decision of a superior if the subordinate causes the superior to make the decision.

Section 1983 requires a connection between a defendant’s actions and the alleged deprivation of rights.

(PC) Bledsoe v. Martinez · filed 2020-01-24

The statute requires that there be an actual connection or link between the actions of the defendants and the deprivation alleged to have been suffered by plaintiff.

Section 1983 requires facts showing that the defendant’s conduct caused the claimed injury.

Merlo v. City of Palo Alto · filed 2020-02-10

The district court properly dismissed Merlo’s action arising from the state court’s entry of the vexatious litigant order because Merlo failed to allege facts sufficient to show that the City of Palo Alto was liable for any due process violation.

Section 1983 requires causation between the defendant’s conduct and the claimed injury in a deliberate indifference claim.

Johnson v. Marlar · filed 2020-03-20

Johnson’s claim also fails, for lack of causation, which is a necessary element of a § 1983 deliberate indifference claim.

Section 1983 requires each defendant’s acts or omissions to proximately cause the plaintiff’s injury.

Butler v. Hesch · filed 2020-03-23

Not only must the conduct deprive the plaintiff of rights and privileges secured by the Constitution, but the actions or omissions attributable to each defendant must be the proximate cause of the injuries and consequent damages that the plaintiff sustained.

Section 1983 requires a causal connection between a defendant’s conduct and the alleged deprivation.

(PC) Sanders v. Grimes · filed 2020-03-24

The Court finds that Plaintiff does not state a cognizable claim because he does not show a causal connection between Defendants’ alleged misconduct and his alleged deprivations, i.e., the denial of appointment of counsel and the forfeiture of bond.

Section 1983 employment discrimination claims require discriminatory intent to be a but-for cause of the adverse employment action.

Farooqi v. New York City Department Of Education · filed 2020-04-09

To succeed on a claim brought under 42 U.S.C. §§ 1981 or 1983, a plaintiff must establish that the defendant’s discriminatory intent was a “but-for” cause of the adverse employment action.

Section 1983 requires a causal connection between a defendant’s conduct and the alleged deprivation of a federal right.

Ash v. Espino · filed 2020-04-21

Moreover, the Eleventh Circuit "'requires proof of an affirmative causal connection between the official's acts or omissions and the alleged constitutional deprivation' in § 1983 cases." ... Given the context of Espino’s alleged statement to Ash and the rest of the Complaint, Ash’s single, conclusory allegation is insufficient to state a claim upon which relief can be granted because Ash has not established a causation between Espino’s statement that Ash’s medication is expensive with the alleged constitutional violation.

Section 1983 requires a causal link between each defendant’s actions or omissions and the alleged deprivation of rights.

(PC) Reed v. Miguel · filed 2020-05-08

To state a claim under section 1983, a plaintiff must show a causal connection or link between the actions of the defendants and the deprivation alleged to have been suffered by the plaintiff. ... Plaintiff also does not state a cognizable claim against Beltran and Cotter because he does not show that their actions or failures to act caused the confiscation or disposal of his property.

Section 1983 requires the defendant to be a but-for cause of the plaintiff’s injury.

McCullough v. The City of Montgomery, Alabama · filed 2020-07-07

A defendant is liable under § 1983 only if it is the but-for cause of the plaintiff's injury.

Section 1983 permits liability for the foreseeable consequences of an officer’s actions, even when a third party causes the immediate harm.

Barefield v. Hillman · filed 2020-07-27

An officer may therefore be liable under § 1983 for the natural consequences of his actions.

A § 1983 plaintiff must show that the defendant’s conduct caused the claimed injury.

Suarez v. Pg&e · filed 2020-09-11

The district court properly granted summary judgment because plaintiffs failed to raise a genuine dispute of material fact as to whether elevated levels of arsenic or uranium had the capacity to cause their alleged injuries, and whether plaintiffs’ alleged injuries resulted from their exposure to elevated levels of arsenic or uranium. See Harper v. City of Los Angeles, 533 F.3d 1010, 1026 (9th Cir. 2008) (“In a § 1983 action, the plaintiff must [] demonstrate that the defendant’s conduct was the actionable cause of the claimed injury.”); In re Hanford Nuclear Rsrv. Litig., 292 F.3d 1124, 1133-34 (9th Cir. 2002) (in a toxic tort case, plaintiff must demonstrate general causation, “whether the substance at issue had the capacity to cause the harm alleged,” and specific causation, “whether a particular individual suffers from a particular ailment as a result of exposure to a substance”).

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Findley v. Pg&e · filed 2020-09-11

The district court properly granted summary judgment because Blowney failed to raise a genuine dispute of material fact as to whether elevated levels of arsenic or uranium had the capacity to cause her alleged injuries, and whether her alleged injuries resulted from her exposure to elevated levels of arsenic or uranium.

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Miller v. Pg&e · filed 2020-09-11

The district court properly granted summary judgment because plaintiffs failed to raise a genuine dispute of material fact as to whether elevated levels of arsenic or uranium had the capacity to cause their alleged injuries, and whether plaintiffs’ alleged injuries resulted from their exposure to elevated levels of arsenic or uranium.

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Nethery v. Pg&e · filed 2020-09-11

The district court properly granted summary judgment because plaintiffs failed to raise a genuine dispute of material fact as to whether elevated levels of arsenic or uranium had the capacity to cause their alleged injuries, and whether plaintiffs’ alleged injuries resulted from their exposure to elevated levels of arsenic or uranium.

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Courtney v. Pg&e · filed 2020-09-11

The district court properly granted summary judgment because plaintiffs failed to raise a genuine dispute of material fact as to whether elevated levels of arsenic or uranium had the capacity to cause their alleged injuries, and whether plaintiffs’ alleged injuries resulted from their exposure to elevated levels of arsenic or uranium.

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Vinson v. Pg&e · filed 2020-09-11

The district court properly granted summary judgment because plaintiffs failed to raise a genuine dispute of material fact as to whether elevated levels of arsenic or uranium had the capacity to cause their alleged injuries, and whether plaintiffs’ alleged injuries resulted from their exposure to elevated levels of arsenic or uranium.

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Riebeling v. Pg&e · filed 2020-09-11

The district court properly granted summary judgment because plaintiffs failed to raise a genuine dispute of material fact as to whether elevated levels of arsenic or uranium had the capacity to cause their alleged injuries, and whether plaintiffs’ alleged injuries resulted from their exposure to elevated levels of arsenic or uranium. See Harper v. City of Los Angeles, 533 F.3d 1010, 1026 (9th Cir. 2008) (“In a § 1983 action, the plaintiff must [] demonstrate that the defendant’s conduct was the actionable cause of the claimed injury.”); In re Hanford Nuclear Rsrv. Litig., 292 F.3d 1124, 1133-34 (9th Cir. 2002) (in a toxic tort case, plaintiff must demonstrate general causation, “whether the substance at issue had the capacity to cause the harm alleged,” and specific causation, “whether a particular individual suffers from a particular ailment as a result of exposure to a substance”).

Section 1983 requires a plaintiff to show that the defendant’s conduct caused the claimed injury.

Holcroft v. Pg&e · filed 2020-09-14

Shirley Holcroft and Sam V. Cabrera appeal pro se from the district court’s summary judgment in their 42 U.S.C. § 1983 action alleging Fourteenth Amendment claims stemming from alleged exposure to elevated levels of arsenic ... and uranium. ... The district court properly granted summary judgment because plaintiffs failed to raise a genuine dispute of material fact as to whether elevated levels of arsenic or uranium had the capacity to cause their alleged injuries, and whether plaintiffs’ alleged injuries resulted from their exposure to elevated levels of arsenic or uranium.

A § 1983 plaintiff must show that the defendant’s conduct caused the claimed injury.

Brown v. Pg&e · filed 2020-09-14

The district court properly granted summary judgment because Brown failed to raise a genuine dispute of material fact as to whether elevated levels of arsenic or uranium had the capacity to cause her alleged injuries, and whether her alleged injuries resulted from her exposure to elevated levels of arsenic or uranium.