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Connick v. Thompson

Supreme Court of the United States

October 6, 2010, Argued; March 29, 2011, Decided

No. 09-571

Case Summary

Procedural Posture

Plaintiff former prisoner sued defendant district attorney under 42 U.S.C.S. § 1983 for failure to train his prosecutors adequately about their duty to produce exculpatory evidence. The U.S. Court of Appeals for the Fifth Circuit affirmed a $ 14 million jury award by an evenly divided en banc court. Certiorari was granted on whether a district attorney's office could have been held liable for failure to train based on a single Brady violation.

Overview

The district attorney's office conceded that, in prosecuting the former prisoner for attempted armed robbery, prosecutors failed to disclose evidence that should have been turned over to the defense under Brady v. Maryland. Because of the former prisoner's attempted armed robbery conviction, he elected not to testify in his own defense in his later trial for murder, and he was again convicted. His convictions were vacated after a reviewing court determined that the withheld evidence, a blood type test, was exculpatory. At a retrial for the murder, the jury found the former prisoner not guilty. The Court agreed with the district attorney that he was entitled to judgment as a matter of law because the former prisoner had not proven that the district attorney was on actual or constructive notice of, and therefore deliberately indifferent to, a need for more or different Brady training. A pattern of similar constitutional violations by untrained employees was necessary to demonstrate deliberate indifference for purposes of failure to train. Because other Brady violations were not similar, they could not have put the district attorney on notice that specific training was necessary.

Outcome

The judgment of the United States Court of Appeals for the Fifth Circuit was reversed. 5-4 Decision; one opinion, one concurrence, one dissent.

LexisNexis® Headnotes

 

 

Civil Rights Law > ... > Scope > Law Enforcement Officials > General Overview

HN1 A district attorney's office may not be held liable under 42 U.S.C.S. § 1983 for failure to train based on a single Brady violation.

 

Civil Rights Law > Protection of Rights > Section 1983 Actions > Scope

HN2 See 42 U.S.C.S. § 1983.

 

Governments > Local Governments > Claims By & Against

Civil Rights Law > Protection of Rights > Immunity From Liability > Respondeat Superior Distinguished

HN3  Claims By & Against

A municipality or other local government may be liable under 42 U.S.C.S. § 1983 if the governmental body itself subjects a person to a deprivation of rights or causes a person to be subjected to such deprivation. But, under § 1983, local governments are responsible only for their own illegal acts. They are not vicariously liable under § 1983 for their employees' actions.

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563 U.S. 51 ; 131 S. Ct. 1350 ; 179 L. Ed. 2d 417 ; 2011 U.S. LEXIS 2594 ; 79 U.S.L.W. 4195; 22 Fla. L. Weekly Fed. S 887

HARRY F. CONNICK, DISTRICT ATTORNEY, et al., Petitioners v. JOHN THOMPSON

Prior History:  [1] ON WRIT OF CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR THE FIFTH CIRCUIT.

Thompson v. Connick, 578 F.3d 293, 2009 U.S. App. LEXIS 17728 (5th Cir. La., 2009)

Disposition: Reversed.