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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