Three major police misconduct cases have offered a conception of the policy or custom test that would limit municipal liability for omission to only the most flagrant misconduct. These opinions suggest that only intentional omissions or direct authorization should subject a municipality to suit under Monell. It is argued that this judicial trend toward requiring proof of municipal intent or affirmative authorization in section 1983 cases must be rejected. By demanding intent, the courts restrict a cause of action that undermines both the viability of Monell and the legislative purpose of the civil rights statute. An intent requirement would preclude recovery for most victims of police brutality who allege municipal liability for their injuries, thus reducing deterrence of misconduct and incentives for institutional improvement. Rather than requiring affirmative authorization or intent, the courts should employ a standard of reasonable foreseeability of harm in addressing municipal responsibility. If a municipal policy of neglect allows a citizen to be abused by police, the victim then can seek the relief that section 1983 was enacted to provide. 84 references.