## Facts

- John Thompson was prosecuted in Orleans Parish in 1985 for attempted armed robbery and later for murder.
- In the robbery case, a crime scene technician collected a blood-stained fabric swatch, and a lab report showed the perpetrator had blood type B while Thompson’s blood type was O.
- Prosecutors did not disclose the blood-type report to the defense.
- After Thompson’s robbery conviction, he chose not to testify at his murder trial to avoid impeachment based on that conviction.
- Thompson was convicted of murder and sentenced to death; he spent 18 years in prison, including 14 years on death row.
- About one month before his execution date, a defense investigator discovered the undisclosed blood evidence.
- Courts vacated the robbery and murder convictions, finding the blood evidence exculpatory; Thompson was later acquitted of murder at retrial.

## Issues

1. Whether a district attorney’s office may be held liable under 42 U.S.C. § 1983 for failure to train prosecutors regarding Brady obligations when the plaintiff proves only a single Brady violation.
2. Whether the record supported a finding of “deliberate indifference” by the policymaker sufficient to treat inadequate training as an official municipal policy under Monell.

## Decision

- The Supreme Court reversed, holding (5–4) that a district attorney’s office may not be held liable under § 1983 for failure to train prosecutors based on a single Brady violation.
- The Court held Thompson did not prove the District Attorney was deliberately indifferent to a known or obvious need for additional Brady training.
- The Court concluded the evidence showed, at most, misconduct by individual prosecutors, which cannot establish municipal liability through respondeat superior.

## Legal Principles

- Under Monell, municipal liability under § 1983 requires that the constitutional injury be caused by an official policy, not merely by actions of employees.
- Failure to train can constitute an actionable policy only when the deficiency reflects deliberate indifference to the rights of persons affected.
- Deliberate indifference generally requires a pattern of similar constitutional violations putting policymakers on notice that training is deficient.
- “Single-incident” failure-to-train liability is available only in rare circumstances where the need for training is so obvious that constitutional violations are a highly predictable consequence.
- In assessing whether the need for training is obvious, courts may consider that prosecutors are professionally obligated and generally expected to know, research, and apply Brady requirements.

## Conclusion

The Court held that the Orleans Parish District Attorney’s Office could not be held liable under § 1983 for failure to train prosecutors on Brady obligations based solely on the Brady violation in Thompson’s case, because a single incident did not establish deliberate indifference or an official policy of inadequate training.


Connick v. Thompson, 563 U.S. 51 (2011)