Connick v. Thompson

2011-03-29

Headline: Court limits municipal liability by ruling a district attorney’s office cannot be sued under federal civil‑rights law for failure to train based on a single undisclosed evidence (Brady) mistake, narrowing remedies for wrongful convictions.

Holding: The Court held a district attorney’s office cannot be held liable under the federal civil‑rights law (42 U.S.C. §1983) for failure to train based on one Brady nondisclosure without evidence of a pattern or an unusually obvious training need.

Real World Impact:

Makes it harder to sue a prosecutor’s office for a single undisclosed piece of evidence.
Requires showing a pattern of violations or an obvious training gap to win such lawsuits.
Leaves intentional misconduct by individual prosecutors still potentially punishable and actionable.

Topics: prosecutorial misconduct, Brady evidence, failure to train, civil rights lawsuit, wrongful conviction

Summary

Background

A man, John Thompson, was prosecuted in New Orleans for an attempted armed robbery and then for murder. Prosecutors failed to disclose a crime-lab report showing the robber’s blood type, Thompson was convicted in both cases, and he spent 18 years in prison, including 14 on death row. One month before his scheduled execution the lab report was found, the convictions were vacated, he was retried and acquitted, and he then sued the Orleans Parish District Attorney’s Office and its head, Harry Connick, under the federal civil‑rights law (42 U.S.C. §1983) for failing to train prosecutors about their duty to disclose exculpatory evidence (the Brady rule).

Reasoning

The Court had to decide whether a single Brady nondisclosure can, by itself, support municipal liability for failure to train. The Court stressed that local governments are liable only for their own policies or for “deliberate indifference” in training. Ordinarily plaintiffs must show a pattern of similar violations. The Court held that the narrow “single-incident” exception applies only in extraordinary cases (like the Canton hypothetical about arming untrained officers) and that prosecutors—who are trained lawyers subject to professional and ethical duties—do not fit that exception here. Because Thompson did not show a pattern of similar Brady failures or that the need for specific training was so obvious, the Court reversed the jury’s verdict for Thompson.

Real world impact

The ruling makes it harder to hold a district attorney’s office liable under §1983 for a single disclosure mistake; plaintiffs generally must show a pattern of past violations or an extraordinarily obvious training gap. The Court left intact that intentional misconduct by individual prosecutors remains separately accountable under criminal, disciplinary, or civil law.

Dissents or concurrances

Justice Scalia (joined by Justice Alito) concurred. Justice Ginsburg (joined by three colleagues) dissented, arguing the record showed pervasive Brady misunderstandings and that the jury’s verdict finding deliberate indifference should stand.