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Qualified Immunity Civil Rights

City of Canton

489 U.S. 378Supreme Court of the United States1989Date unavailable

Summary

City of Canton v. Harris held that a municipality can be liable under § 1983 for failure to train police employees, but only when the failure reflects deliberate indifference to constitutional rights and causes the injury. The case is a foundation of modern Monell municipal-liability doctrine.

Legal Issue

Can a municipality be liable under 42 U.S.C. § 1983 for constitutional violations caused by its failure to train police employees, and if so, what standard applies?

Holding

Yes, in limited circumstances. A municipality may be liable for failure to train only when the training deficiency amounts to deliberate indifference to the constitutional rights of people police encounter, and the deficiency is closely related to, and actually causes, the injury. The Court vacated and remanded.

Rule of Law

A city is not automatically liable because an officer made a bad call. But if the city deliberately ignores an obvious need for training, and that failure causes a constitutional injury, the city can face § 1983 liability.

Court Reasoning

Not yet summarized.

Impact for Officers

City of Canton remains central in civil-rights lawsuits involving police training, detainee medical care, use-of-force policies, supervision, and municipal accountability under Monell.

What Officers Can Do

Not yet summarized.

What Officers Should Avoid

Not yet summarized.

Common Misunderstanding

Not yet summarized.