University of Michigan Law School
Civil Rights Litigation Clearinghouse
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Case Name City of Canton v. Harris JC-OH-0014
Docket / Court 5:80-cv-00018-SHB ( N.D. Ohio )
State/Territory Ohio
Case Type(s) Jail Conditions
Attorney Organization ACLU National (all projects)
Case Summary
This civil rights case is important doctrinally; the United States Supreme Court clarified the standard under which cities and counties could be liable for constitutional violations that occurred due to failure to train or supervise their employees.

On January 8, 1980, Plaintiff, ... read more >
This civil rights case is important doctrinally; the United States Supreme Court clarified the standard under which cities and counties could be liable for constitutional violations that occurred due to failure to train or supervise their employees.

On January 8, 1980, Plaintiff, represented by private counsel, filed a 42 U.S.C. § 1983 suit against the City of Canton, Ohio in the United States District Court for the Northern District of Ohio. The plainiff claimed the police violated her rights when they failed to get her necessary medical attention following arrest.

The 52-year-old plaintiff was arrested for being uncooperative during a traffic stop. When she was brought back for detention, she collapsed repeatedly and acted deliriously. She was left on the floor of the booking facility. After being released, plaintiff suffered a psychiatric episode and required a week of hospitalization. A question of law was certified to the Court of Appeals on the possibility of liability under Monell, and an interlocutory appeal was granted. The U.S. Supreme Court granted certiorari.

In its opinion by Justice White, the United States Supreme Court held that cities and counties could be held liable under Section 1983 for failures to train their officers in the administration of medical care, where that lack of training amounted to deliberate indifference. The Court remanded the case for application of the announced standard. 489 U.S. 378 (1985)

On April 29, 1991, the United States Court for the Northern District of Ohio (Judge Sam Bell) granted summary judgment in favor of the defendants, finding that the lack of training of the officers did not amount to deliberate indifference. The case was closed.

Blase Kearney - 04/09/2012


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Issues and Causes of Action
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Issues
Affected Gender
Female
General
Personal injury
Staff (number, training, qualifications, wages)
Medical/Mental Health
Medical care, general
Mental health care, general
Plaintiff Type
Private Plaintiff
Type of Facility
Government-run
Causes of Action 42 U.S.C. § 1983
Defendant(s) City of Canton
Plaintiff Description A woman arrested for a minor offense who suffered injury because of failure to give medical attention during detention.
Indexed Lawyer Organizations ACLU National (all projects)
Class action status sought No
Class action status granted No
Prevailing Party Defendant
Public Int. Lawyer Yes
Nature of Relief None
Source of Relief None
Form of Settlement None on record
Order Duration not on record
Case Closing Year 1991
Case Ongoing No
Additional Resources
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Case Studies After Decision: Implementation of Judicial Decrees in Correctional Settings
Written: Oct. 01, 1977
By: M. Kay Harris & Dudley P. Spiller (Temple University)
Citation: (1977)
[ Detail ] [ PDF ]

Docket(s)
5:80−cv−00018 (N.D. Ohio) 04/29/1991
JC-OH-0014-9000 PDF | Detail
PACER [Public Access to Court Electronic Records]
General Documents
Order 07/02/1986 (798 F.2d 1414)
JC-OH-0014-0001 PDF | WESTLAW| LEXIS | External Link | Detail
Order (USSC Decision) 02/28/1989 (489 U.S. 378)
JC-OH-0014-0003 PDF | WESTLAW| LEXIS | External Link | Detail
Judges Bell, Samuel H. (N.D. Ohio)
JC-OH-0014-9000
Jones, Nathaniel Raphael (Sixth Circuit)
JC-OH-0014-0001
Lively, Pierce (Sixth Circuit)
JC-OH-0014-0001
Merritt, Frank S. Court not on record
JC-OH-0014-0001
White, Byron Raymond (SCOTUS)
JC-OH-0014-0003
Monitors/Masters None on record
Plaintiff's Lawyers Groves, Gregory (Ohio)
JC-OH-0014-9000
Phillips, Carter G (District of Columbia)
JC-OH-0014-0003
Defendant's Lawyers Albu, Thomas P. (Ohio)
JC-OH-0014-9000
Blomstrom, James L. (Ohio)
JC-OH-0014-9000
Hamann, William J. (Ohio)
JC-OH-0014-9000
Rudovsky, David (Pennsylvania)
JC-OH-0014-0003 | JC-OH-0014-9000
Other Lawyers None on record

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