Woodhull v. Mayor, etc., of the City of New York, 150 N.Y. 450 (1896)
A municipality is not liable for the actions of a police officer performing a public duty mandated by statute, even if the officer is appointed by the municipality.
Summary
The plaintiff, Woodhull, sued the City of New York for false imprisonment after being arrested by a bridge policeman. The New York Court of Appeals held that the city was not liable for the officer’s actions because the officer was performing a public duty under state law, not acting as a servant of the municipality. This case clarifies the distinction between municipal liability for actions performed in a corporate capacity versus those performed as part of a broader public service. It establishes that even when a municipality appoints an individual, if that individual is executing a state-mandated public duty, the municipality is shielded from liability under the doctrine of respondeat superior.
Facts
Woodhull entered a car on the Brooklyn Bridge. As he entered, a bridge police officer, Bishop, closed the sliding door, catching Woodhull’s foot. After freeing his foot, Woodhull questioned Bishop. Bishop then arrested Woodhull, claiming he had been struck. Woodhull was taken to a police station, charged with assault, and later discharged after a trial.
Procedural History
Woodhull sued the City of New York for false imprisonment. The trial court’s judgment was appealed to the General Term. The General Term sided with Woodhull. The City of New York then appealed to the New York Court of Appeals.
Issue(s)
Whether the City of New York is liable for the actions of Bishop, a police officer appointed by the bridge trustees, in arresting Woodhull for an alleged assault.
Holding
No, because Bishop was acting as a public officer performing a state-mandated duty, not as a servant or agent of the City of New York.
Court’s Reasoning
The court reasoned that the liability of a municipal corporation depends on the character of the service performed by the employee. If the employee is performing a public service mandated by statute, the municipality is not liable for their actions, even if the municipality appointed the employee. The court distinguished between actions performed in a corporate capacity for the benefit of the municipality and those performed as part of a broader public service. The court stated, “Police officers appointed by a city are not its agents or servants.” Bishop was appointed under a statute giving him the powers of city policemen and requiring him to protect all travelers, not just city residents. The court rejected the argument that Bishop’s initial act of closing the door (potentially an employee action) was inseparable from the arrest (a police action). The court emphasized that Bishop’s act of placing Woodhull under arrest was performed in his capacity as a policeman, not as an employee of the city. Therefore, the doctrine of respondeat superior does not apply.