Canton v. Harris

In Canton v. Harris (1989) 489 U.S. 378, the plaintiff, like Mr. Greathouse, sought to hold a city "liable under 42 U. S. C. 1983 for its violation of the plaintiff's right, under the Due Process Clause of the Fourteenth Amendment, to receive necessary medical attention while in police custody." (Id. at p. 381.) In adjudicating that claim, the United States Supreme Court set forth the circumstances under which a city could be liable under section 1983 for failure to train its police officers. The Supreme Court held: "The inadequacy of police training may serve as the basis for 1983 liability only where the failure to train amounts to deliberate indifference to the rights of persons with whom the police come into contact. This rule is most consistent with our admonition in Monell v. New York City Dept. of Social Services (1978). . . that a municipality can be liable under 1983 only where its policies are the 'moving force behind the constitutional violation.' Only where a municipality's failure to train its employees in a relevant respect evidences a 'deliberate indifference' to the rights of its inhabitants can such a shortcoming be properly thought of as a city 'policy or custom' that is actionable under 1983. . . . 'Municipal liability under 1983 attaches where-and only where-a deliberate choice to follow a course of action is made from among various alternatives' by city policymakers." (Canton, supra, 489 U.S. at pp. 388-389.) "It may seem contrary to common sense to assert that a municipality will actually have a policy of not taking reasonable steps to train its employees. But it may happen that in light of the duties assigned to specific officers or employees 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 of the city can reasonably be said to have been deliberately indifferent to the need. In that event, the failure to provide proper training may fairly be said to represent a policy for which the city is responsible, and for which the city may be held liable if it actually causes injury." (Canton, supra, 489 U.S. at p. 390.) "In resolving the issue of a city's liability, the focus must be on adequacy of the training program in relation to the tasks the particular officers must perform. That a particular officer may be unsatisfactorily trained will not alone suffice to fasten liability on the city, for the officer's shortcomings may have resulted from factors other than a faulty training program. . . . It may be, for example, that an otherwise sound program has occasionally been negligently administered. Neither will it suffice to prove that an injury or accident could have been avoided if an officer had had better or more training sufficient to equip him to avoid the particular injury-causing conduct. Such a claim could be made about almost any encounter resulting in injury, yet not condemn the adequacy of the program to enable officers to respond properly to the usual and recurring situations with which they must deal. And plainly, adequately trained officers occasionally make mistakes; the fact that they do says little about the training program or the legal basis for holding the city liable." (Canton, supra, 489 U.S. at pp. 390-391.)