City of Canton v. Harris · 489 U.S. 378

holding that city may properly be held liable where policy is moving force behind constitutional violation

How later courts described this case

holding that city may properly be held liable where policy is moving force behind constitutional violation
explaining that failure to train may amount to a policy or custom that is actionable under § 1983 when “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.”
explaining that “[w]ithout some form of notice to the city, and the opportunity to conform to constitutional dictates both what it does and what it chooses not to do, the failure to train theory of liability could completely engulf Monell [v. New York City Dep’t of Soc. Servs., 436 U.S. 658, 98 S.Ct. 2018, 56 L.Ed.2d 611 (1978) ], imposing liability without regard to fault.”
stating that municipal training is actionable where, “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 [municipality] can reasonably be said to have been deliberately indifferent to the need”

Written by the judges who cited it.

Reported abrogated on other grounds by Farmer v. Brennan, 511 U.S. 825 (1994) — not on the Supreme Court's list
489 U.S. 378, 379 (1989), abrogated on other grounds by Farmer v. Brennan, 511 U.S. 825
Supreme Court of the United StatesJun 6, 19943 citing opinionsother groundsunconfirmed confidenceRead it
Questioned by Lewis v. Sacramento County, 98 F.3d 434 (1996)
We noted that an intervening Supreme Court decision, City of Canton, 489 U.S. 378, 109 S.Ct. 1197, had called into question this standard as set forth in Wood I and Fargo.
Court of Appeals for the Ninth CircuitOct 9, 19962 citing opinionsRead it

Distinguished by Connick v. Thompson, 179 L. Ed. 2d 417 (2011)
The reason why the Canton hypothetical is inapplicable
Supreme Court of the United StatesMar 29, 20112 citing opinionsRead it

The opinion

Justice Brennan,

concurring.

The Court’s opinion, which I join, makes clear that the Court of Appeals is free to remand this case for a new trial.