## Facts

- Geraldine Harris was arrested by Canton, Ohio police and taken to a police station in a patrol wagon.
- Upon arrival, officers found her sitting on the wagon floor; when asked if she needed medical attention, she responded incoherently.
- At the station, Harris twice slumped to the floor; officers left her lying on the floor to prevent further falls.
- No medical care was summoned during approximately an hour of custody.
- After release, Harris’s family called an ambulance; she was hospitalized for a week and received outpatient treatment for about a year for emotional ailments.
- Harris presented evidence that shift commanders had sole discretion to decide whether to summon medical care, and that they received no special training beyond first aid to make that determination.

## Issues

1. Whether, and under what standard, a municipality may be liable under 42 U.S.C. § 1983 for constitutional violations resulting from failure to train its employees.
2. Whether a “reckless/grossly negligent” failure-to-train standard is consistent with the rule that municipal liability must rest on a municipal policy or custom rather than respondeat superior.
3. What showing of causation is required to link an identified training deficiency to the plaintiff’s constitutional injury.

## Decision

- The Court held that a municipality may be liable under § 1983 for failure to train only when the failure amounts to deliberate indifference to the rights of persons with whom police come into contact.
- The Court rejected standards based on negligence, gross negligence, or generalized “recklessness” untethered to a conscious municipal policy choice.
- The plaintiff must prove the training deficiency is closely related to the injury and is the “moving force” behind the constitutional violation.
- The Court affirmed the remand for a new trial but vacated to the extent the lower courts approved a liability standard less demanding than deliberate indifference, and remanded for proceedings consistent with the correct standard.

## Legal Principles

- Municipalities are not liable under § 1983 on a respondeat superior theory; liability requires a municipal policy or custom that caused the constitutional deprivation.
- A failure to train can constitute actionable municipal “policy” only when it reflects a deliberate or conscious choice by policymakers amounting to deliberate indifference.
- Deliberate indifference may be shown when the need for training is obvious and the lack of training is likely to result in constitutional violations, or when policymakers are on notice from a pattern of violations and fail to act.
- Causation requires a direct causal link between the training deficiency and the injury; the deficiency must be the moving force behind the violation, not merely a “but for” condition.

## Conclusion

The Court recognized failure-to-train municipal liability under § 1983 but confined it to cases where policymakers’ deliberate indifference to an obvious or known need for training causes a constitutional violation, with the specific deficiency serving as the moving force behind the injury.


City of Canton, Ohio v. Harris, 489 U.S. 378 (1989)