City of Canton v. Harris

In City of Canton v. Harris, 489 U.S. 378 (1989) the United States Supreme Court held that "there are limited circumstances in which an allegation of a 'failure to train' can be the basis for liability under 1983." In that case, the plaintiff had alleged that due to the inadequacy of police training, the City of Canton and its officials violated plaintiff's constitutional right to receive medical attention while in police custody. Id. After the jury ruled in the plaintiff's favor, the city made a motion for judgment notwithstanding the verdict, claiming that a municipality can only be found liable under 1983 where the policy in place is itself unconstitutional. In Rejecting the city's narrow interpretation of 1983, the Canton Court established the following standard for evaluating valid policies alleged to have been unconstitutionally applied: "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 came into contact. . . . 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 . . . . Only where a failure to train reflects a 'deliberate' or 'conscious' choice by a municipality -- a 'policy' as defined by our prior cases -- can a city be liable for such a failure under 1983" Id., 489 U.S. at 388-89, 109 S. Ct. at 1204-05, 103 L. Ed. 2d at 426-27.