[2] Following the Supreme Court decision holding that municipalities were liable under §1983, the city settled for $375,500, to be divided among all women employees placed on forced maternity leave from July 1968 to the time of the case being filed.

[8] The court reasoned that since there was no clear statement in the legislative history justifying the excluding municipalities as "persons" under §1983, such entities could be sued directly under §1983 for policies or customs that violated the U.S.

[9] The United States Supreme Court held that a local government is a "person" that can be sued under §1983: civil action for deprivation of rights.

[1] The Court, however, required that a §1983 claim against a municipal entity be based on the implementation or execution of a "a policy statement, ordinance, regulation, or decision officially adopted and promulgated by that party's officers".

[10] Additionally, the Court held that municipal entities "may be sued for constitutional deprivations visited pursuant to governmental 'custom' even though such a custom has not received formal approval through the body's official decisionmaking channels".

[11] Local governments may not, however, be sued under 1983 for an injury solely by its employees or agents–in other words, a municipality cannot be held liable under §1983 on a respondeat superior theory.

[13] Justice Rehnquist dissented, arguing that adequate justification for overruling Monroe's interpretation of §1983's legislative history did not exist.

[14] In her brief for certiorari, Monell argued that (1) a school board is a "person" within the meaning of §1983; (2) an official withholding wages in violation of the constitution can be compelled to provide back pay under §1983; (3) a district court can award monetary relief in a §1983 action for injury sustained between filing the complaint and the granting of final injunctive relief.

[15] In the reply brief, Petitioners argued that (1) the existence of immunity based on the good faith of the policy at issue was not before the Court; and (2) that relief was authorized against the Board of Education.

[18] In its reply brief against certiorari, the City argued that retroactive application of Title VII to allow damages would "operate unjustly" and that their maternity leave policies were "adopted with the most laudatory motives" to "protect women employees and their unborn children", no matter "how unreasonable or arbitrary they might seem by today's rapidly evolving standards".