Supreme Court Decides Connick v. Thompson
On March 29, 2011, the U.S. Supreme Court decided Connick v. Thompson, No. 09-571, holding that a district attorney's office may not be held liable under 42 U.S.C. §1983 for failure to train its prosecutors based on a single Brady violation.
Criminal defendant John Thompson's capital murder conviction was vacated based on exculpatory evidence that the prosecution should have but did not disclose to Thompson's attorney under the Brady rule. After he was found not guilty on retrial of the murder case, Thompson sued the prosecutor's office for damages under 42 U.S.C. § 1983. Thompson claimed that the prosecutor's office had failed to properly train prosecutors, depending solely on the Brady violation in his case as evidence of that failure. A jury awarded Thompson $14 million in damages, and the Fifth Circuit affirmed by an equally divided en banc court.
The Supreme Court reversed, holding that a single Brady violation is not sufficient to ground a section 1983 action based on failure to train. The Court noted that a section 1983 claim based on a failure to train ordinarily requires a plaintiff to show a pattern of rights violations, and distinguished a hypothetical from Canton v. Harris, 489 U. S. 378 (1989), that would have permitted an inference of culpable failure to train from a city's equipping its police force with guns without training them on constitutional limitations on the use of deadly force. Here, the Court noted, (1) prosecutors were already trained in the law in law school, in CLE courses, and on the job; (2) the Brady line of cases has a number of gray areas, and (3) prosecutors are already ethically bound to know their obligations under Brady. As a result, the Court held that, unlike the Canton hypothetical, recurring constitutional violations are not the "obvious consequence" of failing to provide prosecutors with formal in-house training about how to follow Brady.
Justice Thomas delivered the opinion of the Court, in which Chief Justice Roberts and Justices Scalia, Kennedy, and Alito joined. Justice Ginsburg filed a dissenting opinion, in which Justices Breyer, Sotomayor, and Kagan joined.
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