City of Canton v. Harris

Incident Summary & Facts

In April 1978, Canton, Ohio police arrested Geraldine Harris and took her to the station in a patrol wagon. When the wagon arrived, she was sitting on its floor. Asked whether she needed medical attention, she gave an incoherent answer. During processing she slumped to the floor twice, and officers eventually left her lying there so she would not fall again. No one summoned medical help. After about an hour she was released, and her family’s ambulance took her to a hospital. She was diagnosed with several emotional ailments, hospitalized for a week, and treated as an outpatient for a year.

Harris sued the city under 42 U.S.C. § 1983 for violating her Fourteenth Amendment due process right to necessary medical care in custody. Evidence at trial showed that, under a city regulation, shift commanders had sole discretion to decide whether a detainee needed medical care, and received no special training beyond first aid to make that call. The jury found for Harris only on her § 1983 claim against the city. The Sixth Circuit held that a city may be liable for failure to train when it acts “recklessly, intentionally, or with gross negligence.” It ordered a new trial because the jury instructions may have allowed liability on a respondeat superior theory. The Supreme Court granted certiorari.

This case did not involve a use-of-force encounter. It concerns municipal liability for inadequate training, arising from a detainee’s medical care.

Core Legal Issue

Can a municipality be liable under § 1983 for constitutional violations caused by its failure to train its employees, and if so, what degree of fault must be shown?

The Holding

Yes, but only where the failure to train amounts to “deliberate indifference” to the rights of persons the police come into contact with, and the training deficiency actually caused the injury. The Court rejected the Sixth Circuit’s broader gross-negligence rule, vacated its judgment, and remanded.

The Court’s Analysis:

• Monell causation: A city is liable only when its own policy or custom is the “moving force” behind the violation. Respondeat superior liability does not apply. The Court rejected the city’s argument that only policies that are unconstitutional on their face are actionable.
• Deliberate indifference: A failure to train counts as city “policy” only when it reflects a “deliberate” or “conscious” choice. That can be shown where “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 policymakers . . . can reasonably be said to have been deliberately indifferent.” It can also be shown through a pattern of violations.
• Deadly-force example (footnote 10): Cities know “to a moral certainty” that officers will have to arrest fleeing felons, and they arm officers with firearms. So the need to train on the constitutional limits of deadly force (Tennessee v. Garner) is “so obvious” that failing to provide it could be deliberate indifference.
• What is not enough: It is not enough that one officer was poorly trained, that a sound program was negligently administered, or that better training would have prevented the injury. “Adequately trained officers occasionally make mistakes.” The deficiency must be “closely related to the ultimate injury.”
• Federalism: Lesser standards would amount to de facto respondeat superior liability and draw federal courts into “an endless exercise of second-guessing municipal employee-training programs.”
• Partial dissent (O’Connor, J., joined by Scalia and Kennedy, JJ.): They agreed with the standard but would have entered judgment for the city. Diagnosing mental illness is not a “usual and recurring” situation, and the record showed no pattern of prior violations. Justice Brennan concurred separately to note that the Sixth Circuit was free to order a new trial.