Page 41 - TPA Journal May - June 2018

Legal Issue
Mrs. Harris brought a civil action against the City of Canton Police Department under Chapter
1
42, Section 1983 of the United States Code (42 U.S.C. 1983 or simply Section 1983) alleging
violation of her civil rights to receive medical attention while in police custody. Evidence was

presented to indicate that shift commanders were authorized to determine whether or not a detainees

condition required medical attention. Evidence was also presented to indicate that the shift
commanders were given no training to assist them in making these medical evaluations. Thus, the

legal issue became a quest to define the adequacy of the organizations ability and willingness to

prepare employees through a program of formalized instruction before placing them into new job
classifications.

Decision of the Court
Although there were several procedural issues raised during the proceedings, the United States

Supreme Court ultimately ruled that a municipality may be held liable under Section 1983 for
violation of rights guaranteed by the Federal Constitution, where violations result from the

municipalitys failure to adequately train its employees, only if that failure reflects a deliberate

indifference on the part of the municipality to the constitutional rights of its inhabitants. In the
simplest of terms, by its inaction, the municipality purposefully chose to ignore and decline proper

training for its jailers and their supervisors in a substantive knowledge area that was directly relevant to
the duties of their specific job assignment.

Ramifications for Future Police Operations
The issue of this case and others of similar circumstances is whether a training program is

adequate, and, if it is not, the question becomes whether such inadequate training constitutes city

policy. Although the process was not specifically prescribed in the decision of the court, the content of
a training program should be based on a task analysis to determine which specific knowledge bases,

skills, and abilities should be included in a training program that prepares personnel for a new job

assignment. Because of the specific duties assigned to newly assigned personnel, the need for more or
different training past the usual entry-level instruction becomes obvious. An allegation of training

inadequacy is likely to result from a violation of a citizens constitutional rights and when the city

March/April 2018 www.texaspoliceassociation.com • 866-997-8282 37