Connick v. Thompson

2011-03-29

Headline: Court limits civil liability for prosecutors’ offices, ruling a district attorney’s office cannot be sued for failing to train over a single undisclosed piece of evidence, making it harder for wrongful-conviction victims to get damages.

Holding: The Court held that a local district attorney's office cannot be held civilly liable for failing to train prosecutors based solely on a single failure to disclose evidence, absent proof of a pattern of violations.

Real World Impact:

Makes it harder to win money damages against a prosecutor’s office for a single disclosure failure.
Requires proof of a pattern or obvious training need before municipal liability attaches.
Limits civil claims that rely on one isolated prosecutorial mistake.

Topics: wrongful convictions, prosecutor evidence disclosure, training for prosecutors, local government liability

Summary

Background

John Thompson, a man prosecuted in New Orleans, was convicted in separate trials after prosecutors failed to disclose a crime lab report and a blood-stained swatch. Because of the robbery conviction he did not testify at his murder trial and was later sentenced to death; he spent 18 years in prison. One month before his execution an investigator found the undisclosed report, the convictions were vacated, he was retried and acquitted, and he sued the district attorney’s office claiming it failed to train prosecutors. A jury awarded $14 million; the Fifth Circuit split evenly and this Court reviewed whether one disclosure failure can support a failure-to-train claim.

Reasoning

The Court framed the central question as whether a prosecutor’s office can be held civilly liable for failing to train its lawyers based on one failure to disclose evidence. The Court said municipal liability under civil-rights law requires proof that policymakers were deliberately indifferent to an obvious need for training, which ordinarily demands evidence of a pattern of similar violations. The opinion emphasized that lawyers receive professional training and ethical duties to seek justice and disclose favorable evidence, making single-incident liability for prosecutorial disclosure mistakes unlike the narrow situation the Court imagined in Canton for untrained, armed police. On that basis the Court held the failure-to-train claim could not stand and reversed the lower court’s judgment.

Real world impact

The decision makes it harder for people who suffered a single prosecutorial nondisclosure to win money damages from a district attorney’s office without proof of a pattern or obvious training failure; it preserves local control over prosecutor training and limits liability exposure.

Dissents or concurrances

Justice Scalia (joined by Justice Alito) agreed with the Court and stressed a prosecutor’s intentional misconduct likely caused the nondisclosure; Justice Ginsburg (joined by three other Justices) dissented, arguing the record showed pervasive Brady misunderstandings and that the jury’s verdict of deliberate indifference should stand.