Crowson v. Washington County, 983 F.3d 1166 (10th Cir. Dec. 29, 2020)

In this interlocutory appeal, the Tenth Circuit addressed the scope of pendent appellate jurisdiction and the circumstances in which a claim under 42 U.S.C. § 1983 can be maintained against a municipality without establishing a violation of the plaintiff’s constitutional rights by an employee of the municipality.  The Tenth Circuit clarified that in most cases, “the question of whether a municipality is liable [is] dependent on whether a specific municipal officer violated an individual’s constitutional rights,” but that there is an exception where “the municipal policy devolves responsibility across multiple officers” and “the sum of multiple officers’ actions taken pursuant to municipal policy results in a constitutional violation.”