Canton v. Harris

Supreme Court of United States
489 U.S. 378 (1989)

ELI5:

Rule of Law:

A municipality can be held liable under 42 U.S.C. § 1983 for constitutional violations resulting from its failure to train employees, but only where that failure amounts to deliberate indifference to the constitutional rights of persons with whom its employees will come into contact.

Facts:

In April 1978, Canton Police Department officers arrested Geraldine Harris.
Upon arrival at the police station, Mrs. Harris was found sitting on the floor of the patrol wagon and gave an incoherent remark when asked if she needed medical attention.
Inside the station, Mrs. Harris slumped to the floor on two occasions.
To prevent her from falling again, police officers left her lying on the floor and did not summon any medical attention for her.
After about an hour, Mrs. Harris was released from custody.
Her family provided an ambulance to take her to a hospital, where she was diagnosed with emotional ailments and hospitalized for a week.

Procedural Posture:

Geraldine Harris sued the City of Canton in U.S. District Court (trial court) under 42 U.S.C. § 1983.
The jury found for Mrs. Harris on her § 1983 claim against the city for failure to provide her with medical treatment.
The District Court denied the city's motion for judgment notwithstanding the verdict.
The City of Canton (appellant) appealed to the U.S. Court of Appeals for the Sixth Circuit.
The Sixth Circuit affirmed the legal theory of liability for failure to train under a 'gross negligence' standard but reversed and remanded for a new trial due to potentially misleading jury instructions.
The City of Canton petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.

Premium Content

Subscribe to Lexplug to view the complete brief

You're viewing a preview with Rule of Law, Facts, and Procedural Posture

Issue:

Does a municipality's failure to train its employees constitute a 'policy or custom' that can lead to liability under 42 U.S.C. § 1983 when that failure amounts to deliberate indifference to the constitutional rights of persons with whom the employees will come into contact?

Opinions:

Majority - Justice White

Yes, a municipality's failure to train its employees can serve as the basis for § 1983 liability, but only where the failure to train amounts to deliberate indifference to the constitutional rights of its inhabitants. The Court rejected the argument that a municipality can only be liable if its policy is itself unconstitutional. While a city is not liable under a theory of respondeat superior, an inadequate training program can be considered a 'city policy' when the need for more or different training is so obvious, and the inadequacy so likely to result in the violation of constitutional rights, that the city's policymakers can reasonably be said to have been deliberately indifferent to that need. This 'deliberate indifference' standard is necessary to avoid de facto respondeat superior liability and to prevent federal courts from endlessly second-guessing municipal training programs. The plaintiff must also prove a direct causal link, showing that the specific training deficiency actually caused the constitutional violation.

Concurring in part and dissenting in part - Justice O'Connor

Yes, a municipality's failure to train its employees can create § 1983 liability when it demonstrates deliberate indifference to constitutional rights. I agree with the majority's adoption of the 'deliberate indifference' standard and the causation requirement. However, I dissent from the decision to remand the case for a new trial. The evidence presented by the respondent at trial falls far short of establishing the high degree of fault required by the deliberate indifference standard. There was no evidence of a pattern of past constitutional violations or other circumstances that would have put the city on notice of a need for additional training regarding the medical needs of emotionally disturbed detainees. To allow this claim to proceed based on a single incident would invite jury nullification of Monell and essentially permit respondeat superior liability.

Analysis:

This case clarifies the scope of municipal liability under § 1983, establishing 'deliberate indifference' as the standard for claims based on a failure to train. It carves out a middle ground between automatic respondeat superior liability, which Monell v. Department of Social Services rejected, and the overly restrictive standard that would require the training policy itself to be unconstitutional. The decision provides a viable, though difficult, path for plaintiffs to hold municipalities accountable for systemic failures that lead to constitutional violations. Future cases will focus on defining what constitutes an 'obvious' need for training and what evidence is sufficient to show a pattern of violations that would put a city on notice.

Gunnerbot

AI-powered case assistant

Loaded: Canton v. Harris (1989)

Try: "What was the holding?" or "Explain the dissent"

Premium Feature