City of Canton v. Harris

What Happened

In April 1978, Canton, Ohio police officers arrested Geraldine Harris. When the patrol wagon arrived at the station, Harris was found sitting on the floor. She was asked if she needed medical attention and responded with something incoherent. Once inside the station for processing, she slumped to the floor twice. Eventually, the officers just left her lying on the floor to prevent her from falling again. No one called a doctor. No one summoned medical help. After about an hour, Harris was released. Her family called an ambulance, and she was taken to a hospital, where she was diagnosed with several emotional ailments requiring a week of hospitalization and a year of outpatient treatment.

Harris sued the city under § 1983, alleging that Canton had violated her right under the Due Process Clause to receive necessary medical attention while in police custody. The evidence at trial revealed a telling detail: under city regulations, shift commanders had sole discretion to decide whether a detainee needed medical care. But these commanders received no special training — beyond basic first aid — on how to recognize when a detainee required medical attention. A jury found for Harris.

The city appealed, arguing that it couldn’t be held liable for a “failure to train.” The case reached the Supreme Court on the question of whether Monell liability could extend to a city’s failure to train its employees.

What the Court Decided

Justice White, writing for the majority, held that a municipality can be liable under § 1983 for its failure to train employees — but only when the failure “amounts to deliberate indifference to the constitutional rights of persons with whom the police come into contact.” 489 U.S. at 388.

The Court rejected both extremes. It refused to say that a failure to train can never be the basis for § 1983 liability, but it also refused to adopt the lower courts’ more permissive standard of “recklessness” or “gross negligence.” The “deliberate indifference” standard was chosen because it best fits Monell’s requirement that the city’s own policy be the “moving force” behind the constitutional violation.

The Court explained the framework: First, identify a specific deficiency in the training program. Second, show that the deficiency is closely related to the constitutional injury. Third, show that the failure to train reflects a “deliberate” or “conscious” choice by the city — meaning the need for training was so obvious that the city’s failure to provide it amounts to deliberate indifference.

The Court offered an example: “city policymakers know to a moral certainty that their police officers will be required to arrest fleeing felons. The city has armed its officers with firearms, in part to allow them to accomplish this task. Thus, the need to train officers in the constitutional limitations on the use of deadly force can be said to be ‘so obvious,’ that failure to do so could properly be characterized as ‘deliberate indifference’ to constitutional rights.” 489 U.S. at 390 n.10.

What It Means in Practice

City of Canton opened a crucial pathway for holding cities accountable for systemic failures. Under Monell, a city isn’t liable just because it employs a bad officer. But after Canton, a city that fails to train its officers — knowing they’ll encounter situations where constitutional rights are at stake — can be held liable for the resulting violations.

The “deliberate indifference” standard is demanding but not impossible. You typically prove it in one of two ways:

1. Pattern evidence. Show that officers have repeatedly committed similar violations, putting the city on notice that its training is inadequate. If officers keep violating the same right and the city does nothing to improve training, that’s deliberate indifference.

2. Single-incident liability. In rare cases, you can establish deliberate indifference even without a pattern. Where the need for training is so obvious — like training officers when to use deadly force, or when to summon medical care for someone in custody — a single incident can suffice. But this theory is narrow and hard to win.

Canton also matters because it gives plaintiffs a way around qualified immunity. Individual officers may get QI, but the city cannot. If your failure-to-train claim succeeds, the city pays — even if every individual officer is immunized.

How You Can Use It

Canton is your primary tool for failure-to-train claims against municipalities:

• Identify the specific training gap. You must show a specific deficiency — not that the training program was generally bad, but that the city failed to train officers on the particular issue that led to your injury.
• Key quote: “The inadequacy of police training may serve as the basis for § 1983 liability only where the failure to train in a relevant respect amounts to deliberate indifference to the constitutional rights of persons with whom the police come into contact.” 489 U.S. at 388.
• Show the city knew. Gather evidence of prior incidents, complaints, lawsuits, DOJ reports, and internal investigations showing the city was on notice of the training deficiency.
• Close causal link. The training gap must be closely related to your specific injury. A general allegation that the department’s training was “inadequate” won’t cut it.
• Template: “Under City of Canton v. Harris, 489 U.S. 378, 388 (1989), a municipality is liable for failure to train when the deficiency ‘amounts to deliberate indifference to the constitutional rights of persons with whom the police come into contact.’ Here, Defendant City failed to train its officers on [specific topic], despite [evidence of notice], and this failure directly caused the violation of Plaintiff’s [specific right].”

How It Can Be Used Against You

“Deliberate indifference” is a high bar:

• “Adequate training existed.” The city will produce its training manuals, academy curricula, and in-service training records to show officers were trained on the relevant topic. Even if the training was minimal, the city will argue it was sufficient.
• “Isolated incident.” Without a pattern of similar violations, the city will argue that a single incident doesn’t establish deliberate indifference. One bad outcome doesn’t mean the training was deficient.
• “Officer deviated from training.” The city’s strongest argument is that the officer was trained properly but simply didn’t follow the training. An officer who ignores their training doesn’t prove the training was inadequate — it proves the officer was.
• Causation gap. The city will argue that even if training was deficient, the deficiency didn’t cause your specific injury. “Better training wouldn’t have changed the outcome.”

How to counter: Request the city’s full training records through discovery — not just what they produce, but records of what training officers actually received, how many hours, and when. Depose training officers and supervisors. Compare the city’s training to national standards (POST requirements, IACP guidelines, DOJ best practices). If officers keep making the same mistakes, the pattern speaks louder than any training manual.