Case Brief: City of Canton v. Harris, 489 U.S. 378 (1989)

Carolanne Hines
20 October 2013


City of Canton v. Harris, 489 U.S. 378 (1989)

CASE FACTS

Geraldine Harris was arrested and brought to the Canton Police Department for speeding. During the traffic stop, Mrs. Harris became uncooperative with law enforcement officers and was arrested. She was transported to the police department in a police wagon. When they arrived at the police department, she was sitting on the floor of the wagon. She looked unsteady on her feet and officers asked if she required medical assistance, to which she gave an unintelligible answer.
While the officers were processing her in, she slumped to the floor twice and on the second time, the officers left her on the floor to keep her from falling again and injuring herself. It took about an hour to process her in, to which no medical assistance was acquired for her. Then, police released her from custody to a hospital and she was transported there via ambulance. Mrs. Harris was diagnosed with emotional issues and admitted to the hospital for a week. She subsequently received therapy for her issue for a year.
Later, Mrs. Harris filed a §1983 action against the police department stating that her Fourteenth Amendment rights were violated, specifically the due process clause, because the police department did not seek immediate medical care.

ISSUE/ISSUES

What criteria must be met for a plaintiff to prevail in a §1983 action resulting from failure to train in context of respondeat superior?
  • The defendant must display deliberate indifference.
  • With the city/municipality acting as a superior, the policy that resulted in the injury of the plaintiff must prove the policy is inadequate for the needs of the city and also represents the city.
  • The deficient policy must be directly related to the plaintiff's injury
  • The policymakers must be aware that the policy is deficient and causing the enactor of said policy to cause injury to another.

COURT DECISION AND RATIONALE

When the Supreme Court reached their decision regarding the case of Mrs. Harris, they created the criteria so that the municipality/city had some immunity against §1983 actions that would overload the system. The city/municipal government would not be able to function if they had to second guess every decision. The Supreme Court held “To adopt lesser standards of fault and causation would open municipalities to unprecedented liability under § 1983; would result in de facto respondeat superior liability, a result rejected in Monell; would engage federal courts in an endless exercise of second-guessing municipal employee training programs, a task that they are ill-suited to undertake; and would implicate serious questions of federalism.”
The Supreme Court detailed their criteria:
“...a city is not liable under § 1983 unless a municipal "policy" or "custom" is the moving force behind the constitutional violation. Only where a failure to train reflects a "deliberate" or "conscious" choice by the municipality can the failure be properly thought of as an actionable city "policy." Monell will not be satisfied by a mere allegation that a training program represents a policy for which the city is responsible. Rather, the focus must be on whether the program is adequate to the tasks the particular employees must perform, and if it is not, on whether such inadequate training can justifiably be said to represent "city policy." Moreover, the identified deficiency in the training program must be closely related to the ultimate injury. Thus, respondent must still prove that the deficiency in training actually caused the police officers' indifference to her medical needs.”
The Supreme court reversed the decision of the lower courts and remanded that the case is open for a new trial.
The District Court rejected all of her other claims except for the §1983 claim that the city violated her Fourteenth Amendment right to due process by denying her medical care The lower courts came to their decision based on a city regulation that stated supervisors were responsible for assessing whether or not a detainee required medical attention. Also, it was admitted through testimony that police supervisors had no real training to determine whether or not a detainee was in need of medical attention or not. The decision stated “The evidence, construed in a manner most favorable to Mrs. Harris, could be found by a jury to demonstrate that the City of Canton had a custom or policy of vesting complete authority with the police supervisor of when medical treatment would be administered to prisoners. Further, the jury could find from the evidence that the vesting of such carte blanche authority with the police supervisor, without adequate training to recognize when medical treatment is needed, was grossly negligent, or so reckless that future police misconduct was almost inevitable or substantially certain to result.”
The Sixth Circuit Court held “a municipality is liable for failure to train its police force, [where] the plaintiff... prove[s] that the municipality acted recklessly, intentionally, or with gross negligence.” However, when the case reached the Court of Appeals, the court reversed the lower court's decision by indicating that the jury might have been mislead by the idea of respondeat superior – the instructions the jury led them to believe that a city could be held liable because of respondeat superior and nothing else. The city of Canton petitioned for certiorari because of the verdict in the Sixth Circuit Court and how the jury was mislead by the “impermissible broadening of municipal liability under § 1983”

DISSENTING AND CONCURRING OPINIONS

The opinion of the court was delivered by Justice White, who was backed by Justices Rehnquist, Blackmun, Marshall, Stevens, and Brennan on most of the decision. Justice Brennan filed a concurring opinion. Justice O'Connor filed an opinion that was a partial concurrence and a partial dissent. Also, n certain parts Justices Scalia and Kennedy dissented, but not on the full decision.
The focal points of Justice White's opinion are the fact that for a plaintiff to prevail in a §1983 action against a city due to a policy, the policy itself must be unconstitutional. He further states that the policy, which puts the assessment of medical care of a detainee in the hands of a police supervisor is not unconstitutional because it is not depriving the person with whom the policy is referring to of their right to due process. In fact, it is ensures the assessment of medical care is in the hands of a supervisor, and not a subordinate. Justice White also states that for failure to train to become a successful §1983 action there must be a display of deliberate indifference on behalf of the city/municipality/supervising body.
Justices O'Connor, Scalia, and Kennedy concurred with most of Justice White's Opinion, however they did have some dissenting thoughts. They felt the case did not need to be remanded for a new trial. Justice O'Connor stated in her dissent, “This case comes to us after a full trial during which respondent vigorously pursued numerous theories of municipal liability, including an allegation that the city had a "custom" of not providing medical care to detainees suffering from emotional illnesses. Respondent thus had every opportunity and incentive to adduce the type of proof necessary to satisfy the deliberate indifference standard we adopt today. Rather than remand in this context, I would apply the deliberate indifference standard to the facts of this case. After undertaking that analysis below, I conclude that there is no evidence in the record indicating that the city of Canton has been deliberately indifferent to the constitutional rights of pretrial detainees.”
Justice O'Connor also dissented in that she felt it was obvious that the city policy was flawed. She states “this Court has not yet addressed the precise nature of the obligations that the Due Process Clause places upon the police to seek medical care for pretrial detainees who have been physically injured while being apprehended by the police... There are thus no clear constitutional guideposts for municipalities in this area, and the diagnosis of mental illness is not one of the "usual and recurring situations with which [the police] must deal." The lack of training at issue here is not the kind of omission that can be characterized, in and of itself, as a "deliberate indifference" to constitutional rights.”

CASE SIGNIFICANCE AND ANALYSIS

This case is important in that it changes the criteria with which cities and municipalities are liable. It gives municipalities a greater amount of immunity because for a plaintiff to prevail in a failure to train due to deliberate indifference issue they have to meet specific criteria.
This case relates to in Vineyard v. Murray County of Georgia, 990 F.2d 1203 (11th Cir.1993), Robinson v. City of St. Charles, 972 F.2d 974 (9th Cir. 1992), and Connick v. Thompson, 131 S. Ct. 1350 (2011).
In Vinyard v. Murray County (1993), the federal district court found that the sheriff's department was deliberately indifferent, then the Eleventh Circuit Court of Appeals that the county had inadequate policies including training, supervision, and discipline. Because of this, the plaintiff was awarded $175,000 in compensatory damages and $60,000 in punitive damages.
In Robinson v. City of St. Charles (1992), there had to be proof that the city knew their policies were inadequate. This means that a city cannot be held liable for deliberate indifference stemming from a single incident.
And, in Connick v. Thompson (2011), the courts found Thompson guilty of attempted robbery and murder in separate incidents. He was sentenced to death and spent 14 years on death row. A month prior to his execution, new DNA evidence was uncovered which exonerated him of murder. The attorney's office moved to stay the execution because of the armed robbery charge. However, the Louisiana Court of Appeals reversed the decision to stay the execution, stating that the armed robbery conviction violated his constitutional rights in that he was prevented from defending himself by testifying at his murder trial. This lead to Thompson filing a §1983 action against the DA's office, stating that the misconduct of Attorneys Connick, Williams, and others resulted in his incarceration. The misconduct consisted of not reporting lab results during his armed robbery trial. This is required by Brady v. Maryland (1963). Thompson was awarded $14 million in damages and $1 million in attorney's fees. The decision was appealed to the Fifth Circuit, which held the decision of the lower court. When certiorari was granted and the Supreme Court Reviewed the case, the decision was reversed because of the “single incident” criteria for proving deliberate indifference. The Supreme Court held “A district attorney’s office may not be held liable under §1983 for failure to train its prosecutors based on a single Brady violation.”
The decision is important to the criminal justice system in that it gives departments and cities/municipalities more immunity from frivolous lawsuits claiming failure to train. Justice White stated this in his opinion. The system would be backed up and nonfunctional if every employee and supervisor had to second guess themselves while making a split-second decision. However, Justice O'Connor also pointed out that this has a negative effect concerning civil rights when she discussed what is “obvious”.

STANDARDS

The decision creates a new standard to which cities/municipalities can be held liable under §1983 for failure to train incidents.





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