Since its inception in 1871, and characterization in the Supreme
Court case of Monroe v. Pape, 42 U.S.C. § 1983 has caused turmoil
among commentators concerned with this statute's application in the
area of constitutional rights.
Russell, Holiday Hunt
"The Search for a Section 1983 Right Under the Dormant Commerce Clause,"
Nova Law Review: Vol. 15:
1, Article 11.
Available at: https://nsuworks.nova.edu/nlr/vol15/iss1/11