Roberts v. City of Shreveport

Majority - Edith H. Jones

Yes, Chief Prator is entitled to qualified immunity, dismissing him from the action in his individual capacity. Supervisory officials are not liable for the actions of subordinates based on vicarious liability under § 1983. To establish § 1983 liability against supervisors, plaintiffs must show (1) the police chief failed to supervise or train the officer, (2) a causal connection between the failure to supervise or train and the violation of the plaintiff’s rights, and (3) the failure to supervise or train amounted to deliberate indifference to the plaintiff’s constitutional rights, as established in City of Canton v. Harris. While the jury's prior finding that Officer Rivet's conduct was objectively reasonable despite violating Carter's rights does not preclude a failure-to-train claim against the chief, the plaintiffs failed to provide sufficient evidence for either inadequate training or deliberate indifference. The court found plaintiffs' allegations of inadequate training regarding crossing guard duties, the Tennessee v. Garner standard, and the meaning of 'deadly force' unavailing. Officer Rivet received hundreds of hours of professional instruction, including extensive training in the use of force, and the Shreveport Police Department had a comprehensive deadly force policy. Mere proof that an injury could have been prevented with better training is insufficient, and testimonial embarrassment from supervisors not recalling exact standards does not prove systemic inadequacy. The plaintiffs also failed to demonstrate a pattern of unconstitutional conduct by Officer Rivet; prior instances of him brandishing a firearm were deemed fundamentally different from the use of deadly force, and the only other deadly force incident was found legally justified. Newspaper articles offered as evidence were inadmissible hearsay. The case also did not fit the narrow 'single incident exception' from Bryan County v. Brown, which requires highly predictable consequences from a failure to train and the failure being the 'moving force' behind the violation, given Officer Rivet's significant training and lack of evidence of prior improper deadly force use. Furthermore, Chief Prator is immune from state law claims. Louisiana law extends qualified immunity principles analogous to § 1983 for state constitutional claims, and its discretionary immunity statute (§ 9:2798.1) protects public officials for policy-based discretionary acts. The Chief's training and supervisory decisions involved policy choices, and no specific law dictated his course of action, thus meeting both prongs of Louisiana’s discretionary immunity test.