City of Canton v Harris: Landmark Municipal Liability Case explained, including failure-to-train liability and §1983 standards.
The City of Canton v. Harris (1989) is a landmark Supreme Court case that established when a municipality can be held liable under 42 U.S.C. §1983 for a failure to train employees properly.
In this Civil Law case, the Court held that municipalities could be liable for constitutional violations when their lack of training is evidence of a municipality’s deliberate indifference to citizens’ constitutional rights and results in a constitutional injury.
What Is City of Canton v Harris?
The Supreme Court’s decision in City of Canton v Harris is a landmark ruling on mediation of lawsuits against cities over police training and other issues related to police liability.
The decision created barriers for plaintiffs in holding their municipalities accountable for violations of the Constitution committed by their employees prior to this case.
The basis of municipal liability for constitutional violations was very limited; plaintiffs had to come forth with direct evidence of the city’s involvement in the violation of the Constitution.
The Court addressed whether or not municipalities could be held liable when the City was supposed to provide its employees with adequate training and, therefore, their employees were violating the constitutional rights of other citizens.
The conclusion of the Court was that a City could be held liable under certain very specific conditions for its failure to adequately train its employees.
Why This Supreme Court Case Matters
The City of Canton v. Harris case held great implications beyond simply the specific case in question. The Court’s ruling established:
- Cities may be liable to suit for failing to properly train their employees.
- An inadequate training policy does not create liability on its own.
- There must be an established showing of deliberate indifference by the employer in failing to train its employees.
- The failure to properly train employees must be the direct cause of a constitutional violation by the employees.
In the years following the City of Canton v. Harris case, attorneys, law students, judges, police departments, and civil rights advocates continue to refer to the case in their efforts to understand and assess municipal liability claims.
Background of the Case
To better comprehend the Court’s ruling, it is necessary to comprehend the background events leading up to the formation of this action.
This action centers on an incident between Geraldine Harris and the police in Canton, Ohio, during 1978.
Even though many of the summaries, at first glance, would seem to indicate there was no ambiguity about the nature of this incident, when taken together, there are details that show the information was actually much different than presented in the summaries.
Who Was Geraldine Harris?
One very many times overlooked facts about the City of Canton v. Harris decision are about Geraldine Harris herself. Geraldine Harris was a law-abiding citizen who had no criminal record prior to her arrest.
Some of Geraldine’s characteristics:
- Homemaker (age – 52)
- High School Graduate
- Mother of 8 children
- All of her children attended and graduated from college
- 1 daughter became a physician
- 1 daughter was later elected to serve as a judge
- Son, Ronnie Mazel Harris, received the Gold Medal in Olympic boxing competition in 1968.
- Geraldine was also recently recognized as the “Mother of the Year” in the City of Canton.
Importantly, Geraldine has never been diagnosed with a mental illness or emotional disorder. Before trial, it is also necessary to provide readers important potentially missing background information often omitted from reader-friendly, quick reference legal case summaries.
The Events Leading to the Lawsuit
On April 26, 1978, Geraldine Harris was taking her daughter to school and was pulled over by police for speeding. Normally a speeding offence results in a ticket, but the situation escalated rather rapidly.
Conflicting Accounts
The police allege that Harris:
- Was uncooperative and did not produce her driver’s license
- Was upset and refused to cooperate with the officers
- Created difficulties throughout the encounter
Harris has a different story
- She alleged she was verbally abused by the officers
- She alleged she was physically abused by the officers
- She alleged the officers acted unreasonably during the encounter
As is often the case in litigation, it was difficult to determine exactly what happened. At the end of the day, there were no charges, either felony or misdemeanor, filed against Harris.
What Happened While Harris Was in Custody?
The police transported Harris to their station following her arrest. Once in custody:
- Harris was observed lying down in the back seat of the police vehicle.
- She had collapsed on several occasions while in custody.
- She gave incoherent responses to the officers’ questions.
- The officers did not attempt to obtain medical attention for Harris.
Ultimately, she was taken to the hospital via ambulance by her family. Her doctors later
diagnosed her with serious mental illness. These incidents are the basis for her lawsuit against the City.
The Legal Issue Before the Supreme Court
The legal issue in this case was straightforward but also very important. It concerned whether or not municipalities could be held liable under Section 1983 if they do not properly train their employees.
The Supreme Court has agreed to determine whether the failure of a city to provide its employees with proper training gives rise to municipal liability in the case of a constitutional violation.
The Supreme Court’s Decision
In 1989, the Supreme Court ruled on whether municipalities could be held liable for violating the Constitution due to inadequate training of their employees. The Court created a high hurdle that needed to be overcome to establish municipality liability, with the Court stating that a city could only be liable for its failure to train when it was demonstrated that the city had acted with: “Deliberate Indifference.” This phrase became the basis for modern-day failure to train lawsuits.
The Court ruled that policymakers must have known there was an obvious need for the additional training but did not provide additional training. This means that it is insufficient for a Plaintiff to prove negligence on the part of city officials; the Plaintiff must prove that city officials knowingly disregarded a substantial risk.
Understanding the Deliberate Indifference Standard
While “deliberate indifference” sounds like a technical term, it can really be defined simply. Suppose a staircase in a school continues to have reports of it being unsafe and the administration is aware that there may be a high likelihood of students injuring themselves by using that staircase; however, they refuse to fix it.
As a result, a student is injured because of the unsafe staircase. Most individuals would see that this action constituted a failure on the school’s part to address an evident hazard. The same reasoning was used by the U.S. Supreme Court in the case of City of Canton, Ohio v. Harris, where it determined that municipalities have an obligation to train their employees appropriately where there is clear evidence that adequate training is necessary and where the municipality has chosen knowingly not to provide that training.
The Failure-to-Train Doctrine Explained
The landmark case of City of Canton v Harris established the current failure to train doctrine.
In order for the plaintiff to prevail, they generally must prove:
- The city’s training program was inadequate.
- The city or its officials knew there was a need for more training but failed to provide it.
- The lack of training caused the constitutional violation.
Typically, a plaintiff must establish all three of these elements. A plaintiff’s inability to meet just one of the three elements can result in the plaintiff’s failure to prevail in his/her claim.
Justice O’Connor’s Influential Concurrence
Though not part of the majority opinion, her concurrence held great sway.
She opined that the plaintiff should show that cities failed to train employees in reference to:
- Repeatedly occurring clear constitutional duties.
- Duties that officials knew had previously been violated.
These are ideas often cited by courts in ruling upon claims of municipal liability.
How City of Canton v Harris Changed Municipal Liability
In making this decision, the plaintiffs had difficulty connecting the misconduct of their municipal employees with the policies of their municipalities. The court created a way for municipalities to be liable, while at the same time, imposed very strict limitations.
The court sought to create a balance between two competing interests:
Protecting Constitutional Rights
Citizens should have some means of redress if government officials violate their rights as guaranteed by the U.S. Constitution.
Preventing Unlimited Municipal Liability
Municipalities should not be exposed to lawsuits each time an employee makes an error. The court established the doctrine of “deliberate indifference” as the solution.
The Lasting Impact on Civil Rights Litigation
Today, more than 30 years after it was decided, the City of Canton v. Harris case is still one of the most often referred to when looking at issues related to municipal liability.
Many cases have been affected by this case in some way; examples would include:
- Police Misconduct
- Prison Operations
- Excessive Force Allegations
- Medical Care while in Custody
- Civil Rights Litigation
- Government Employee Training Policies
Law Schools continue to teach this case because of the impact it has had on how Section 1983 cases are brought today.
What Happened to Geraldine Harris?
Harris’ life did not finish with his decision from the Supreme Court. More than 10 years after her arrest, the Supreme Court subsequently overturned her original jury decision with regard to the city.
At the time when this ruling was issued, Harris had begun suffering from a disease called cancer (at least 10 years after her arrest) and there was never a retrial.
Harris died in July 1991. Harris is an example of how the study of constitutional law has a real impact on people’s lives through the means of long-term effects of a violation of their constitutional rights through government actions.
FAQs
What is City of Canton v Harris?
City of Canton v. Harris is a 1989 U.S. Supreme Court case that determined when municipalities can be held liable under Section 1983 for their failure to properly train their employees.
What does deliberate indifference mean?
Deliberate Indifference is when a public official acts with “deliberate indifference” to an obvious risk of a constitutional violation occurring due to lack of adequate training by ignoring that risk.
Why is City of Canton v Harris important?
City of Canton v. Harris established the legal framework for the failure to train lawsuits against municipalities.
Is City of Canton v Harris still relevant today?
City of Canton v. Harris remains relevant today with decisions made in civil rights and police misconduct cases citing this case regularly.
What constitutional issue was involved?
The issue in City of Canton v. Harris was whether the municipality could be liable under Section 1983 due to inadequate training regarding the medical care of detainees.
Key Takings
- Canton v. Harris is a key Supreme Court ruling from 1989.
- The ruling founded the ‘failure to train’ principle for determining if a city is civilly liable.
- City governments may have civil liability under Section 1983.
- To demonstrate civil liability via failure to train, the plaintiff must prove that the city was deliberately indifferent to the need for training.
- The inadequate training must show direct causation between the training and the constitutional violation.
- Canton continues to be a key part of the law governing civil rights and municipal liability.
Additional Resources
- Supreme Court Opinion: Read the complete Supreme Court decision in City of Canton v. Harris, 489 U.S. 378 (1989).
- 42 U.S.C. §1983 Overview: Learn how federal civil rights claims are brought against government officials and municipalities.
