In 2008, Frederick, Md. sheriff deputies espy woman sitting on curb eating a sandwich before work, demand identification. She provides El Salvadoran ID, and the deputies discover she has an outstanding immigration warrant, so they arrest and jail her. Fourth Circuit (2013): Unconstitutional seizure. But back to the district court to determine whether the deputies’ actions were official gov’t policy. District Court (2018): They were! The county (plus its sheriff and deputies) are liable for the constitutional violations.