City of Canton, Ohio v. Harris (1988)
- Docket
- 86-1088
- Decided
- 1988-01-01
Summary
Question: Is a municipality liable for failure to provide adequate training to an employee that resulted in a deprivation of constitutional rights? Conclusion: Yes. Justice Byron R. White wrote the opinion for the 6-3 majority. The Court held that municipalities may be liable for inadequate training of employees, but only when “the failure to train amounts to deliberate indifference” to the constitutional rights of the people with whom the employees will interact. A municipality is then only liable when the failure to train is a deliberate choice on the part of the city. In his concurring opinion, Justice William J. Brennan, Jr. makes clear that the Court of Appeals may remand the case for a new trial. In an opinion concurring in part and dissenting in part, Justice Sandra Day O’Connor agreed with the majority’s holding regarding the municipality’s liability for a conscious failure to train. However, she argued that it was unnecessary to remand the case to the Court of Appeals. The Court should simply apply the “deliberate indifference” standard to the facts of the case. Justice Antonin Scalia and Justice Anthony M. Kennedy joined in Justice O’Connor’s opinion.