City of Oklahoma v. Tuttle
1985 U.S. LEXIS 26, 85 L. Ed. 2d 791, 471 U.S. 808 (1985)
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Rule of Law:
Proof of a single incident of unconstitutional activity by a non-policymaking municipal employee is not sufficient to impose liability on the municipality under 42 U.S.C. § 1983 for having a 'policy' of inadequate training or supervision. To establish such liability, a plaintiff must prove the existence of a municipal policy or custom and an affirmative causal link between that policy and the constitutional deprivation, which requires more than inferring the policy from the single incident alone.
Facts:
- Albert Tuttle placed an anonymous telephone call to the police reporting a robbery in progress at the We’ll Do Club in Oklahoma City, providing a description of himself as the robber and stating the robber had a gun.
- Officer Julian Rotramel, a member of the Oklahoma City police force for 10 months, was the first officer to respond to the robbery call.
- Inside the bar, Rotramel encountered Tuttle, who matched the description from the bulletin, and attempted to detain him.
- The barmaid informed Officer Rotramel that no robbery had occurred.
- Tuttle broke away from Rotramel, ignored commands to 'halt,' and went outside.
- Rotramel followed Tuttle outside and saw him crouched on the sidewalk with his hands in or near his boot.
- When Tuttle began to rise from the crouch, Rotramel shot and killed him, later testifying that he believed Tuttle had a gun and his life was in danger.
- A toy pistol was discovered in Tuttle's boot at the hospital.
Procedural Posture:
- Rose Marie Tuttle, the widow of Albert Tuttle, sued Officer Rotramel and the City of Oklahoma City in the United States District Court for the Western District of Oklahoma under 42 U.S.C. § 1983.
- A jury at the trial court level returned a verdict in favor of Officer Rotramel but against the City of Oklahoma City, awarding $1.5 million in damages to the respondent.
- The City of Oklahoma City, as appellant, appealed the judgment to the United States Court of Appeals for the Tenth Circuit.
- The Court of Appeals affirmed the trial court's judgment, holding that a single, unusually excessive use of force could warrant an inference of a municipal policy of inadequate training.
- The City of Oklahoma City successfully petitioned the Supreme Court of the United States for a writ of certiorari.
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Issue:
Does a single, isolated incident of the use of unconstitutional excessive force by a police officer, without more, suffice to establish an official municipal 'policy or custom' of inadequate training, thereby rendering the municipality liable for damages under 42 U.S.C. § 1983?
Opinions:
Majority - Justice Rehnquist
No. A single incident of unconstitutional conduct by a municipal employee is insufficient to establish an official municipal policy or custom of inadequate training sufficient for liability under § 1983. The Court's holding in Monell v. New York City Dept. of Social Services requires that municipal liability be based on a 'policy or custom,' which was intended to prevent liability based on a theory of respondeat superior. The jury instruction in this case was erroneous because it allowed the jury to infer a policy of 'inadequate training' and municipal fault ('deliberate indifference' or 'gross negligence') solely from one 'unusually excessive use of force.' Such an inference would permit liability to be imposed on a municipality simply for employing one 'bad apple,' without any proof that the city's policymakers made a conscious choice to adopt a flawed training program. There must be an affirmative link between the municipal policy and the particular constitutional violation alleged, and proof of a single incident is not enough to establish either the policy's existence or the causal connection.
Concurring - Justice Brennan
No. A jury finding of municipal liability cannot be based solely on a single, isolated incident of police misconduct. To establish liability under § 1983, a plaintiff must prove causation, which involves showing both the existence of a municipal policy and that this policy was the cause of the constitutional deprivation. Allowing a jury to infer the existence of a deficient training policy from the isolated misconduct of a single, low-level officer would effectively permit liability on a respondeat superior basis, which was expressly rejected in Monell. The misconduct could be attributable to numerous factors other than municipal policy, such as the officer's own mental state. Unlike in Monell or Owen v. City of Independence, where the official policy was directly proven, here the jury instruction improperly allowed the policy itself to be inferred from the very incident it was supposed to have caused, without requiring independent evidence of the city's fault.
Dissenting - Justice Stevens
Yes. A single incident of unconstitutional conduct by a police officer acting in an official capacity should be sufficient to hold the municipality liable. The Court's 'policy or custom' requirement, originating from dicta in Monell, is a judicial invention not found in the text of § 1983 and is contrary to the common law principles of respondeat superior that were well-established when the statute was enacted. An officer acting 'under color of state law' engages in state action precisely because of his employment by the municipality. Therefore, the municipality, as the employer, should be held responsible for the constitutional torts of its employees committed during the performance of their official duties. This approach would provide fair compensation to victims, deter future violations, and properly place primary responsibility on the municipal entity rather than complicating litigation with nebulous inquiries into 'policy.'
Analysis:
This decision significantly heightened the evidentiary burden for plaintiffs seeking to hold municipalities liable under § 1983 for unconstitutional acts of their employees based on a 'failure to train' theory. It firmly established that liability cannot be inferred from a single incident alone, thereby reinforcing the rejection of respondeat superior liability from Monell. The case forces plaintiffs to engage in discovery to find and present direct, independent evidence of a flawed municipal policy or a pattern of similar incidents, shifting the focus from the single officer's act to the municipality's systemic culpability. This ruling makes it substantially more difficult to win 'failure to train' cases and requires a clear distinction between individual employee misconduct and an official policy that is the 'moving force' behind a constitutional violation.
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