Supreme Court of the United States
Harry F. Connick v. John Thompson
March 29, 2011179 L. Ed. 2d 417
Summary
The Court held that a local government cannot be held liable under 42 U.S.C. § 1983 for failing to train prosecutors based on a single Brady violation absent a pattern of similar constitutional violations or an exceptionally obvious need for training. Because prosecutors are licensed attorneys equipped and ethically obligated to understand and research legal duties, the alleged need for additional Brady instruction did not satisfy the stringent deliberate-indifference standard. Justice Ginsburg, dissenting, would have upheld the verdict because the record supported finding pervasive Brady misunderstandings and deliberately indifferent training and supervision practices.
Holding
- Municipal liability for failure to train based on a single Brady violation. A municipality’s failure to train prosecutors about Brady obligations does not establish deliberate indifference based on a single violation when the plaintiff has not shown a pattern of similar constitutional violations.
- Applicability of the single-incident exception to Brady training for prosecutors. The narrow single-incident exception does not apply to a failure to provide prosecutors with specific Brady training because licensed attorneys are trained and professionally obligated to identify, interpret, and apply legal requirements.
Docket No. 09-571