Failure to Train

What It Is

Failure to train is one way to hold a city or municipality liable under § 1983 through Monell liability. The idea is simple: if a city fails to properly train its police officers, and that failure leads to constitutional violations, the city itself can be held responsible.

The landmark case is City of Canton v. Harris, 489 U.S. 378 (1989).

What You Must Prove

Failure-to-train claims have a high bar. You must show:

1. A training program is inadequate — The city’s training was deficient in a specific area related to the constitutional violation you suffered.

2. Deliberate indifference — The city knew (or obviously should have known) that the lack of training would lead to constitutional violations. Simple negligence is not enough.

3. Moving force causation — The training failure was the “moving force” behind your specific constitutional injury. You must connect the training gap directly to what happened to you.

How to Show Deliberate Indifference

There are two main ways:

Pattern of Violations

The most common approach: show that officers have repeatedly violated rights in the same way, putting the city on notice that training was inadequate. For example, multiple complaints about officers using chokeholds might show the city knew its use-of-force training was deficient.

Single-Incident Liability

In rare cases, a single incident can establish deliberate indifference if the need for training was so obvious. City of Canton used the example of arming officers with guns but providing no training on when to use deadly force — the risk of constitutional violations is so predictable that failing to train is deliberately indifferent.

The Supreme Court reinforced the high standard in Connick v. Thompson, 563 U.S. 51 (2011), making single-incident claims very difficult to win.

Practical Tips

• Request training records during discovery. Ask for the city’s use-of-force training curriculum, the hours of training provided, and any records of past complaints.
• Look for a pattern. Gather evidence of prior similar incidents — internal affairs complaints, prior lawsuits, news reports.
• Be specific. Identify the exact training deficiency — don’t just say “the city failed to train.” Specify what training was missing (e.g., de-escalation techniques, proper handcuffing, medical attention for detainees).
• Connect it to your injury. Show how better training would have prevented what happened to you.

Key Takeaway

A city can be liable when its failure to train officers shows deliberate indifference to constitutional rights — but you must prove a specific training gap, notice, and a direct connection to your harm.