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Connick v. Thompson - 563 U.S. 51, 131 S. Ct. 1350 (2011)

Rule:

Plaintiffs who seek to impose liability on local governments under 42 U.S.C.S. § 1983 must prove that action pursuant to official municipal policy caused their injury. Official municipal policy includes the decisions of a government's lawmakers, the acts of its policymaking officials, and practices so persistent and widespread as to practically have the force of law. These are actions for which the municipality is actually responsible. In limited circumstances, a local government's decision not to train certain employees about their legal duty to avoid violating citizens' rights may rise to the level of an official government policy for purposes of § 1983. A municipality's culpability for a deprivation of rights is at its most tenuous where a claim turns on a failure to train. A policy of inadequate training is far more nebulous, and a good deal further removed from the constitutional violation, than was the policy in Monell v. New York City Dept. of Social Servs. To satisfy the statute, a municipality's failure to train its employees in a relevant respect must amount to deliberate indifference to the rights of persons with whom the untrained employees come into contact. Only then can such a shortcoming be properly thought of as a city policy or custom that is actionable under § 1983.

Facts:

The Orleans Parish District Attorney's Office conceded that in prosecuting respondent Thompson for attempted armed robbery, prosecutors violated Brady v. Maryland by failing to disclose a crime lab report. Because of his robbery conviction, Thompson elected not to testify at his later murder trial and was convicted. A month before his scheduled execution, the lab report was discovered. A reviewing court vacated both convictions, and Thompson was found not guilty in a retrial on the murder charge. Thompson then filed suit against the district attorney's office under 42 U.S.C. § 1983, alleging that the Brady violation was caused by the office's deliberate indifference to an obvious need to train prosecutors to avoid such constitutional violations. The district court held that, to prove deliberate indifference, Thompson did not need to show a pattern of similar Brady violations when he could demonstrate that the need for training was obvious. The jury found the district attorney's office liable for failure to train and awarded Thompson damages. The Fifth Circuit affirmed by an equally divided court.

Issue:

Can a district attorney's office be held liable for its alleged failure to train prosecutors?

Answer:

No.

Conclusion:

The Court held that a district attorney's office may not be held liable under § 1983 for failure to train its prosecutors based on a single Brady violation. According to the Court, the district attorney was entitled to judgment as a matter of law because Thompson 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. The Court posited that a pattern of similar constitutional violations by untrained employees was necessary to demonstrate deliberate indifference for purposes of failure to train. In the case at bar, other Brady violations were not similar, hence, they could not have put the district attorney on notice that specific training was necessary.

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