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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