In this 5-4 opinion, the Supreme Court reversed a $14 million dollar judgment and found that a district attorney’s office may not be held liable under §1983 for failure to train its prosecutors based on a Brady violation.
The Orleans Parish District Attorney’s Office failed to disclose evidence that should have been turned over to the defense under Brady v. Maryland. The evidence was a lab report that showed that the blood of the robber was type B as found on a swatch of clothing worn by the victim. Thompson's blood type is O. Thompson was convicted at his first trial of armed robbery. Because of that conviction Thompson elected not to testify in his own defense in his second trial for murder, and he was again convicted. Thompson spent 18 years in prison, including 14 years on death row. One month before Thompson’s scheduled execution, his investigator discovered the undisclosed evidence from his armed robbery trial. The reviewing court determined that the evidence was exculpatory, and both of Thompson’s convictions were vacated.
After he was released from prison, Thompson sued the District Attorney's Office. The jury awarded Thompson $14 million, and the Court of Appeals for the Fifth Circuit affirmed. The Supreme Court granted certiorari to decide whether a district attorney’s office may be held liable under §1983 for failure to train based on a single claim as opposed to a pattern of similar violations.
The central issue behind the majority opinion is whether the District Attorney, was deliberately indifferent to the need to train attorneys under his authority. The Court concluded that this case does not fall within the narrow range of "single-incident" liability hypothesized in precedent as a possible exception to the pattern of violations necessary to prove deliberate indifference in §1983 actions alleging failure to train.
The Supreme Court states that the District Court should have granted the District Attorney judgment as a matter of law on the failure-to-train claim because Thompson did not prove a pattern of similar violations that would "establish that the ‘policy of inaction’ [was] the functional equivalent of a decision by the city itself to violate the Constitution."
The central issue behind the majority opinion is whether the District Attorney, was deliberately indifferent to the need to train attorneys under his authority. The Court concluded that this case does not fall within the narrow range of "single-incident" liability hypothesized in precedent as a possible exception to the pattern of violations necessary to prove deliberate indifference in §1983 actions alleging failure to train.
The Supreme Court states that the District Court should have granted the District Attorney judgment as a matter of law on the failure-to-train claim because Thompson did not prove a pattern of similar violations that would "establish that the ‘policy of inaction’ [was] the functional equivalent of a decision by the city itself to violate the Constitution."
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