Reply to this statement, "The application of Section 1983 to litigation began changing dramatically with the U.S. Supreme Court case of Monroe v. Pape (1961). Prior to the Monroe (1961) ruling, bringing suit against criminal justice professionals was difficult. The U.S. Supreme Court decision broadened the meaning of the statute to include actions of criminal justice professionals who violated constitutional rights while acting under public policy or law. Now, Section 1983 could be used to sue state and local officials who misused their positions of power to violate constitutional rights (Linebach & Kovacsiss, 2022). In law enforcement there are multiple stressors related to psychological research, for example, the Police Stress Theory which discusses the stressors that officers face on their day to day while on duty. This could be violence that is seen while one duty or the stress of making an error or misconduct while on duty. This not only stresses while on duty but can carry over to their day to day lives. Where this covers the aspect for what officers experience while on the job and the effects it has, it does not cover all aspects for police officers. Another psychological research theory is Implicit Bias which stated that unconscious prejudices can determine their decision making leading to civil rights violating behavior. Meaning this argues that officers behavior or actions is based on racial or other biases beliefs