City of Canton v. Harris

Supreme Court of the United States · 1989 · Torts

TortsSection 1983Municipal LiabilityFailure to Train§ 1983municipal liabilityfailure to traindeliberate indifference

Facts

Geraldine Harris was arrested by Canton police officers and brought to the police station in a patrol wagon. At the station, she was found sitting on the floor, made an incoherent remark when asked if she needed medical attention, and slumped to the floor twice after being brought inside; officers left her on the floor and did not summon medical care. Evidence showed that shift commanders had sole discretion to decide whether a detainee required medical care and that they were not given special training beyond first-aid training to determine when to summon medical assistance for an injured detainee. Harris later sued the city under § 1983, alleging a deprivation of her Fourteenth Amendment right to necessary medical attention while in police custody.

Issue

Can a municipality ever be liable under 42 U.S.C. § 1983 for constitutional violations resulting from its failure to train municipal employees? If so, what level of fault and causation must be shown before inadequate training constitutes a municipal policy or custom actionable under § 1983?

Rule

A municipality may be liable under § 1983 for failure to train its employees only where the failure to train amounts to deliberate indifference to the rights of persons with whom those employees come into contact. The identified deficiency in the training program must be closely related to the ultimate injury, and the plaintiff must prove that the deficiency actually caused the constitutional violation; lesser standards would impermissibly collapse municipal liability into respondeat superior.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Tulsa, officers of the Red Mesa Police Department are routinely issued Tasers and assigned to make street arrests. The department provides no instruction at all on constitutional limits governing use of force during arrests, even though supervisors know officers regularly confront fleeing suspects. An officer repeatedly shocks an unarmed suspect who posed no immediate threat, causing a clear constitutional violation.

If the suspect sues the city under § 1983 on a failure-to-train theory, which is the strongest basis for municipal liability?

Explanation. A municipality may be liable for failure to train only in limited circumstances: the omission must amount to deliberate indifference, and the identified training deficiency must be closely related to and actually cause the constitutional injury. When officers are certain to confront recurring situations implicating constitutional limits, the need for training can be so obvious that policymakers' failure to provide it may qualify as municipal policy. Liability does not rest on respondeat superior, does not require a facially unconstitutional written policy, and is not established merely because more training might have helped.