Connick v. Thompson

PETITIONER: Harry F. Connick, District Attorney, et al.
RESPONDENT: John Thompson
LOCATION: Orleans Parish District Attorney's Office

DOCKET NO.: 09-571
DECIDED BY: Roberts Court (2010-2016)
LOWER COURT: United States Court of Appeals for the Fifth Circuit

CITATION: 563 US 51 (2011)
GRANTED: Mar 22, 2010
ARGUED: Oct 06, 2010
DECIDED: Mar 29, 2011

ADVOCATES:
J. Gordon Cooney Jr. - for the respondent
S. Kyle Duncan - for the petitioners

Facts of the case

John Thompson sued the Orleans Parish District Attorney's Office, the District Attorney, Harry Connick, in his official and individual capacities, and several assistant district attorneys in their official capacities under 42 U.S.C § 1983 in a Louisiana federal district court. Mr. Thompson served fourteen years on death row for a crime he did not commit because prosecutors failed to turn over blood work in a related case. The jury awarded Mr. Thompson $14 million against Mr. Connick in his official capacity. On appeal, an en banc U.S. Court of Appeals for the Fifth Circuit rendered a tie vote and; thus by rule, affirmed the district court.

Question

Can a prosecutor's office be held liable for the illegal conduct of one of its prosecutors, on the theory that the office failed to adequately train its employees, when there has been only one violation resulting from that deficient training?

Media for Connick v. Thompson

Audio Transcription for Opinion Announcement - March 29, 2011 (Part 2) in Connick v. Thompson
Audio Transcription for Oral Argument - October 06, 2010 in Connick v. Thompson

Audio Transcription for Opinion Announcement - March 29, 2011 (Part 1) in Connick v. Thompson

Clarence Thomas:

This case comes to us on a writ of certiorari to the United States Court of Appeals for the Fifth Circuit.

Respondent John Thompson was convicted of attempted armed robbery in 1985.

Because of that conviction, Thompson chose not to testify in his own defense in his later trial for murder.

He was convicted and sentenced to death.

While Thompson was in prison, his investigator discovered a crime report from his robbery case.

The district attorney's office agreed with Thompson that according to Brady versus Maryland, the prosecutors should have disclosed the lab report to Thompson during his trial.

Because Thompson's blood type did not match that in the crime lab report, his robbery conviction was reversed.

Thompson's murder conviction was also reversed on the ground that the armed robbery conviction had unconstitutionally deprived him of the right to testify in his own defense at his murder trial.

In 2003, Thompson was retried for the murder and found not guilty.

Thompson then sued the district attorney's office for damages under 42 U.S.C. 1983.

He alleged that the district attorney fails to train the prosecutors adequately about their constitutional duty under Brady to produce exculpatory evidence.

And that this lack of training had caused the prosecutor's failure to disclose a lab report in his case.

The jury awarded Thompson $14 million and the Court of Appeals for the Fifth Circuit affirmed by an equally divided en banc court.

In an opinion filed with the clerk today, we reversed the judgment of the Court of Appeals.

Under our precedence of plaintiff seeking to hold the Government liable for failure to train must show deliberate indifference.

Deliberate indifference requires proof that policy makers disregarded the known or obvious fact that a particular omission in their training program would cause employees to violate citizens' constitutional rights.

Ordinarily, a pattern of constitutional violations by untrained employees is necessary to show deliberate indifference.

Thompson does not argue that any pattern of previous similar Brady violation exists in this case.

In Canton versus Harris, this Court left open the possibility that failure to train liability could be based on a single incident when the need for training was patently obvious such as when a city does not tell police officers about the constitutional limits on the use of deadly force.

Today, we conclude that Canton's hypothetical exception does not apply to claims about failure to train prosecutors.

Constitutional violations are not necessarily the consequence of a failure to train prosecutors.

Attorneys are trained in the law and equipped to interpret and apply legal principles and exercise legal judgment.

Prosecutors, in particular, are ethically required to know and follow Brady.

In the absence of a pattern of previous Brady violations that would demonstrate that further specific training is necessary, a district attorney is not deliberately indifferent when he relies on prosecutor's professional training and ethical obligations.

A district attorney's office therefore may not be held liable under Section 1983 for failure to train based on a single Brady violation.

Justice Scalia has filed a concurring opinion in which Justice Alito joins.

Justice Ginsburg has filed a dissenting opinion in which Justices Breyer, Sotomayor and Kagan joined.