City of Canton v. Harris
Supreme Court of the United States
November 8, 1988, Argued ; February 28, 1989, Decided
[*380] [***421] [**1200] JUSTICE WHITE delivered the opinion of the Court.
In this case, we are asked to determine if a municipality can ever be liable under 42 U. S. C. § 1983 for constitutional violations resulting from its failure to train municipal employees. We hold that, under certain circumstances, such liability is permitted by the statute.
[****8] [*381] I
In April 1978, respondent Geraldine Harris was arrested by officers of the Canton Police Department. Mrs. Harris was brought to the police station in a patrol wagon.
When she arrived at the station, Mrs. Harris was found sitting on the floor of the wagon. She was asked if she needed medical attention, and responded with an incoherent remark. After she was brought inside the station for processing, Mrs. Harris slumped to the floor on two occasions. Eventually, the police officers left Mrs. Harris lying on the floor to prevent her [**1201] from falling again. No [***422] medical attention was ever summoned for Mrs. Harris. After about an hour, Mrs. Harris was released from custody, and taken by an ambulance (provided by her family) to a nearby hospital. There, Mrs. Harris was diagnosed as suffering from several emotional ailments; she was hospitalized for one week and received subsequent outpatient treatment for an additional year.
Some time later, Mrs. Harris commenced this action alleging many state-law and constitutional claims against the city of Canton and its officials. Among these claims was one seeking to hold the city liable under 42 U. S. C. § 1983 [****9] for its violation of Mrs. Harris' right, under the Due Process Clause of the Fourteenth Amendment, to receive necessary medical attention while in police custody.
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489 U.S. 378 *; 109 S. Ct. 1197 **; 103 L. Ed. 2d 412 ***; 1989 U.S. LEXIS 1200 ****; 57 U.S.L.W. 4270
CITY OF CANTON, OHIO v. HARRIS et al.
Prior History: [****1] CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT.
Disposition: 798 F. 2d 1414, vacated and remanded.
municipality, training, failure to train, deliberate indifference, employees, custom, constitutional right, municipal liability, medical care, detainees, constitutional violation, fault, medical treatment, policymakers, deliberately, deprivation, police officer, circumstances, indifferent, training program, courts, rights, join, violation of constitutional right, gross negligence, municipal policy, respondeat, causation, emotional, questions
Civil Rights Law, Protection of Rights, Section 1983 Actions, Scope, Civil Procedure, Jurisdiction on Certiorari, Considerations Governing Review, Federal Court Decisions, Governments, Local Governments, Claims By & Against, Immunity From Liability, Local Officials, General Overview, Respondeat Superior Distinguished, Scope, Government Actions, Law Enforcement Officials, Police Power, Employees & Officials