Law of the Case: Canton v. Harris, U.S. Supreme Court, No. 86-1088, 57 LW 4270 (From Crime to Court: Police Officer's Handbook, P 5-13, May 1989, Joseph C Coleman)

• NCJ Number: 117301
• Author(s): J C Coleman
• Date Published: 1989
• Length: 9 pages
• Corporate Author: South Carolina Educational Television Network; South Carolina Criminal Justice Acad
• Publication Format: Document
• Publication Type: Training (Handbook/Manual)
• Language: English
• Country: United States of America

Annotation

This legal analysis of Canton vs. Harris focuses on the condition of Harris at the time of arrest, case law precedent, determining when municipal policies violate constitutional rights, the issue of deliberate indifference in employee training, and the direct link between a city's training program and injury.

Abstract

After a 1978 traffic arrest, Geraldine Harris was brought to the Canton police station but no medical attention was provided. Harris was later taken to a nearby hospital where she was diagnosed as suffering from several emotional ailments. Harris sued the city of Canton and its officials, holding the city liable for violating her rights under the Fourteenth Amendment to receive necessary medical care while in police custody. The District Court issued a verdict against the city, and the Sixth Circuit Court affirmed the District Court's analysis upon appeal. However, the Court of Appeals stated that the plaintiff must prove that lack of training was reckless or grossly negligent to the point of depriving the individual of constitutional rights. The city then appealed to the U.S. Supreme Court, arguing that the Sixth Circuit Court's holding represented an impermissible broadening of municipal liability. The U.S. Supreme Court ruled in February 1989 that a municipality may be liable if city personnel are deliberately indifferent to constitutional rights and where 'failure to train' reflects a conscious choice or policy by a municipality. (See NCJ 117300-117302 for additional information.)