Okla. City v. Tuttle - 471 U.S. 808, 105 S. Ct. 2427 (1985)

Rule:

Proof of a single incident of unconstitutional activity is not sufficient to impose municipal liability, unless proof of the incident includes proof that it was caused by an existing, unconstitutional municipal policy, which policy can be attributed to a municipal policymaker. Otherwise the existence of the unconstitutional policy, and its origin, must be separately proved. But where the policy relied upon is not itself unconstitutional, considerably more proof than a single incident will be necessary in every case to establish both the requisite fault on the part of the municipality, and the causal connection between the "policy" and the constitutional deprivation.

Facts:

A police officer shot and killed the administratrix's husband outside of a bar. Thereafter, the administratrix brought a lawsuit against the officer and the municipality under 42 U.S.C.S. § 1983, alleging that her husband was deprived of his constitutional rights. The United States District Court for the Western District of Oklahoma instructed the jury that the city could be held liable only if the incident had been caused by a municipal "policy," but that a single, unusually excessive use of force could support an inference of gross negligence or indifference by a municipality in the training and supervision of police. The jury returned a verdict in favor of the police officer but against the municipality. The circuit court also ruled in favor of the administratrix. The United States Court of Appeals for the Tenth Circuit affirmed, holding that the District Court's instruction properly stated the standard for municipal liability. The Court granted a writ of certiorari. 

Issue:

Could the municipality be held liable for damages under 42 U.S.C.S. § 1983 on the basis of a single isolated incident of the use of excessive force by a police officer? 

Answer:

No.

Conclusion:

On certiorari, the United States Supreme Court reversed, holding that a single isolated incident of the use of excessive force by a police officer cannot establish an official policy or practice of the municipality sufficient to render it liable for damages under 1983, and that the verdict below, which could have been based solely on the contrary instruction of the District Court, was therefore invalid. According to the Court, the administratrix was required to prove that policymakers deliberately chose an inadequate training program. The administratrix also had to prove that the policy was unconstitutional.