City of Oklahoma City v. Tuttle

Supreme Court of the United States · 1985 · Federal Courts

Federal CourtsSection 1983Municipal Liability42 U.S.C. § 1983Monellmunicipal policy or customsingle incidentinadequate training

Facts

Officer Rotramel, an Oklahoma City police officer on the force for 10 months, responded to a reported robbery at a bar and shot Albert Tuttle outside the bar; a toy pistol later fell from Tuttle's boot at the hospital. Respondent sued the officer and the city under § 1983, alleging deprivation of constitutional rights and seeking to hold the city liable on a theory of inadequate training and supervision. Respondent introduced evidence about the shooting and expert testimony that Rotramel's training was grossly inadequate, but introduced no evidence that Rotramel or any other officer had been involved in a similar incident. The trial court instructed the jury that, although policy ordinarily cannot be inferred from a single incident, a single unusually excessive use of force could warrant an inference that it was attributable to inadequate training or supervision amounting to deliberate indifference or gross negligence.

Issue

Whether a single isolated incident of unconstitutional conduct by a police officer can, by itself, support municipal liability under § 1983 by permitting the jury to infer a municipal policy of inadequate training or supervision. Also, whether the city had preserved its objection to the single-incident jury instruction.

Rule

Under § 1983 and Monell, a municipality may be held liable only when the constitutional deprivation was caused by an official municipal policy or custom attributable to a municipal policymaker, and that policy must be the moving force behind the violation. Proof of a single incident of unconstitutional activity is not sufficient to impose municipal liability unless the proof of that incident itself includes proof that it was caused by an existing unconstitutional municipal policy attributable to a municipal policymaker; where the alleged policy is not itself unconstitutional, considerably more proof than a single incident is necessary to establish both municipal fault and causation, including at least an affirmative link between the policy and the particular constitutional violation.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

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

In Tulsa, Officer Nina Flores, a patrol officer with no policymaking authority, allegedly used excessive force during a single traffic stop, breaking Darren Cole's jaw. Cole sues the city under § 1983 and proves only the details of that encounter, offering no evidence of prior similar incidents, no formal city directive, and no action by any city policymaker.

Is the city most likely liable under § 1983 on this record?

Explanation. Municipal liability under § 1983 cannot rest on respondeat superior. The majority held that proof of a single incident of unconstitutional activity is insufficient unless the proof of that incident itself includes proof that it was caused by an existing unconstitutional municipal policy attributable to a municipal policymaker. Here, the plaintiff proved only one officer's conduct and no policymaker-linked policy or custom.