Municipal failure to train or supervise amounting to deliberate indifference (City of Canton v. Harris)

OR · 42usc1983:policy.failure-to-train

Under City of Canton v. Harris (489 U.S. 378 (1989)) and Connick v. Thompson (563 U.S. 51 (2011)), failure to train is actionable only where it amounts to "deliberate indifference to the rights of persons with whom the [untrained employees] come into contact" and a municipal employee actually committed an underlying constitutional violation.

Exact element source

custom, or usage,
Source: docroot/ir/usc/title42.jsonl#title42_sec1983; Unicode character offsets [115:132] (end exclusive); SHA-256 88fe01322b9d94860a669ec452f558146e2745845070bc43583671ce12acb2bb.

All variants

Recorded DB variant labels, including zero-count variants
VariantDescriptionMerits instance blocksDistinct casesExample cases (up to 3 per group)
derivative-of-deprivation/derivative-claim-falls-with-officer-claim1
Satisfied 0; not satisfied 1; excluded context 0
1/f-supp-2d/367/1175-01 — United States District Court for the Northern District of Ohio · 2005 — not
failure-to-train/deliberate-indifference-to-employee-safety1
Satisfied 1; not satisfied 0; excluded context 0
1/us/503/0115-01 — Supreme Court of the United States · 1992 — satisfied
failure-to-train/no-showing-need-for-training-was-obvious0
Satisfied 0; not satisfied 0; excluded context 1
0No counted merits examples

Excluded context examples: /f-supp-2d/367/1175-01 — United States District Court for the Northern District of Ohio · 2005 — applied/alternative

How courts decided this element

Annotation blocks, including explicitly excluded context
CaseElementHolding and scopeVariantExact source quotations
/f-supp-2d/367/1175-01 — United States District Court for the Northern District of Ohio · 2005Municipal failure to train or supervise amounting to deliberate indifference (City of Canton v. Harris)not
Counted merits instance
applied / merits

basis: law; party: City of Warren; count: Count III, Monell failure to train (City); theory: derivative of the officers' violation (Heller): no underlying constitutional violation, no municipal liability; subject: party=City of Warren; count=Count III, Monell failure to train (City); theory=derivative of the officers' violation (Heller): no underlying constitutional violation, no municipal liability

Heller rule: no constitutional violation by an employee, so no municipal liability; the policy element itself is not examined on this route. A footnote notes that officer immunity alone would NOT have shielded the city.
derivative-of-deprivation/derivative-claim-falls-with-officer-claim
A plaintiff suing a municipality under Section 1983 for the acts of one of its employees must prove: (1) that a municipal employee committed a constitutional violation, and (2) that a municipal policy or custom was the moving force behind the constitutional deprivation.
Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [39812:40082] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

It is well established that a municipality cannot be held liable under Section 1983 for the acts of an employee where the municipal employee committed no constitutional violation.
Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [40372:40551] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

This Court’s finding that Chief Mandopoulos did not use excessive force against Mr. Dye as a constitutional matter precludes a finding in favor of the plaintiff on his Fourth Amendment claim against the City.
Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [42192:42400] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

/f-supp-2d/367/1175-01 — United States District Court for the Northern District of Ohio · 2005Municipal failure to train or supervise amounting to deliberate indifference (City of Canton v. Harris)not
Excluded from merits counts
applied / alternative

basis: no-evidence; party: City of Warren; count: Count III, Monell failure to train (City); theory: Canton deliberate indifference (footnote: "Additionally..."); subject: party=City of Warren; count=Count III, Monell failure to train (City); theory=Canton deliberate indifference (footnote: "Additionally...")

Independent second ground, given in a footnote: even apart from Heller, plaintiff answered the summary-judgment motion with no evidence of deliberate indifference. Split from the Heller block in v1 (QA1).
failure-to-train/no-showing-need-for-training-was-obvious
Mr. Dye failed to make any showing that the purported need for a policy or additional training was "so obvious, and the inadequacy so likely to result in the violation of constitutional rights,” that the city was “deliberately indifferent to the need.”
Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [50200:50452] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

/us/503/0115-01 — Supreme Court of the United States · 1992Municipal failure to train or supervise amounting to deliberate indifference (City of Canton v. Harris)satisfied
Counted merits instance
applied / merits

basis: assumed

Policy element assumed arguendo; the point of the opinion is that Canton "deliberate indifference" goes to municipal responsibility only and does not supply the underlying constitutional violation.
failure-to-train/deliberate-indifference-to-employee-safety
The complaint also alleged that a prior incident had given the city notice of the risks of entering the sewer lines and that the city had systematically and intentionally failed to provide the equipment and training required by a Texas statute.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [1305:1549] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: fact; polarity: supports; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

The city is not vicariously liable under §1983 for the constitutional torts of its agents: It is only liable when it can be fairly said that the city itself is the wrongdoer.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [8208:8382] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Instead, we concluded that if a city employee violates another’s constitutional rights, the city may be liable if it had a policy or custom of failing to train its employees and that failure to train caused the constitutional violation.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [10489:10725] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: rule; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

We assume for the purpose of decision that the allegations in the complaint are sufficient to provide a substitute for the doctrine of respondeat superior as a basis for imposing liability on the city for the tor-tious conduct of its agents, but that assumption does not confront the question whether the complaint has alleged a constitutional violation.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [11573:11927] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Evidence kind: held; polarity: not recorded; absent flag: 0; quoted-rule flag: 0 (1 = tagged; 0 = not tagged)

Court interpretations

interpretation

Instead, we concluded that if a city employee violates another’s constitutional rights, the city may be liable if it had a policy or custom of failing to train its employees and that failure to train caused the constitutional violation.

/us/503/0115-01 — Supreme Court of the United States · 1992

Instead, we concluded that if a city employee violates another’s constitutional rights, the city may be liable if it had a policy or custom of failing to train its employees and that failure to train caused the constitutional violation.
Source: docroot/ir/caselaw/us_503.jsonl#/us/503/0115-01; Unicode character offsets [10489:10725] (end exclusive); SHA-256 cdcb0d53dc7d297333c59be23c4699c1e9264a24434e59748ddb5fbaeb69f046.

Under City of Canton v. Harris (489 U.S. 378 (1989)) and Connick v. Thompson (563 U.S. 51 (2011)), failure to train is actionable only where it amounts to "deliberate indifference to the rights of persons with whom the [untrained employees] come into contact" and a municipal employee actually committed an underlying constitutional violation.

interpretation

A plaintiff suing a municipality under Section 1983 for the acts of one of its employees must prove: (1) that a municipal employee committed a constitutional violation, and (2) that a municipal policy or custom was the moving force behind the constitutional deprivation.

/f-supp-2d/367/1175-01 — United States District Court for the Northern District of Ohio · 2005

A plaintiff suing a municipality under Section 1983 for the acts of one of its employees must prove: (1) that a municipal employee committed a constitutional violation, and (2) that a municipal policy or custom was the moving force behind the constitutional deprivation.
Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [39812:40082] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.

Under City of Canton v. Harris (489 U.S. 378 (1989)) and Connick v. Thompson (563 U.S. 51 (2011)), failure to train is actionable only where it amounts to "deliberate indifference to the rights of persons with whom the [untrained employees] come into contact" and a municipal employee actually committed an underlying constitutional violation.

interpretation

It is well established that a municipality cannot be held liable under Section 1983 for the acts of an employee where the municipal employee committed no constitutional violation.

/f-supp-2d/367/1175-01 — United States District Court for the Northern District of Ohio · 2005

It is well established that a municipality cannot be held liable under Section 1983 for the acts of an employee where the municipal employee committed no constitutional violation.
Source: docroot/ir/caselaw/f_supp_2d_367.jsonl#/f-supp-2d/367/1175-01; Unicode character offsets [40372:40551] (end exclusive); SHA-256 a691ce28535a7c307a739684761f22ce436f22e5bc46c2a6c0235a33bf67199f.

Under City of Canton v. Harris (489 U.S. 378 (1989)) and Connick v. Thompson (563 U.S. 51 (2011)), failure to train is actionable only where it amounts to "deliberate indifference to the rights of persons with whom the [untrained employees] come into contact" and a municipal employee actually committed an underlying constitutional violation.