Connick v. Thompson Case Brief

Facts of the Case

Petitioner, the Orleans Parish District Attorney’s Office, conceded that in prosecuting respondent Thompson for attempted armed robbery, prosecutors violated, by failing to disclose a crime lab report. Because of his robbery conviction, Thompson elected not to testify at his later murder trial and was convicted. A month before his scheduled execution, the lab report was discovered. The reviewing court vacated both convictions and Thompson was found not guilty in a retrial on the murder charge. He then filed suit against the district attorney’s office alleging that theviolation was caused by the office’s deliberate indifference to an obvious need to train prosecutors to avoid such constitutional violations. The District Court held that, to prove deliberate indifference, Thompson did not need to show a pattern of similarviolations when he could demonstrate that the need for training was obvious. The jury found the district attorney’s office liable for failure to train and awarded Thompson $14 million in damages. On appeal, the Fifth Circuit affirmed.

Question

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CONCLUSION

“No. A divided Supreme Court held that a prosecutor’s office could not be held liable for the illegal conduct of one of its prosecutors when there has been only one violation resulting from that deficient training. Justice Clarence Thomas wrote the majority opinion for the court. In a dissent read from the bench, Justice Ruth Bader Ginsburg, joined by Justices Stephen Breyer, Sonia Sotomayor and Elena Kagan, argued that the “what happened here, the Court’s opinion obscures, was no momentary oversight, no single incident of a lone officer’s misconduct.” Instead, Ginsburg contended, evidence “established persistent, deliberately indifferent conduct for which the District Attorney’s Office bears responsibility under §1983.”Justice Antonin Scalia joined the majority opinion but filed a separate concurrence, joined by Justice Samuel Alito, which responded to the dissent.”

Case Information

Citation: 563 US 51 (2011)
Granted: Mar 22, 2010
Argued: Oct 6, 2010
Decided: Mar 29, 2011
Case Brief: 2011