Deliberate Indifference
Canton v. Harris: Understanding Deliberate Indifference in Law Enforcement
When it comes to police liability, the U.S. Supreme Court case City of Canton v. Harris (1989) stands as a critical decision. While many people are familiar with Graham v. Connor or Tennessee v. Garner in the context of use of force, Canton v. Harris set important precedent for how agencies themselves can be held accountable—not just individual officers.
The Case Background
In Canton v. Harris, Geraldine Harris was arrested in Canton, Ohio. During her time in custody, she exhibited signs of emotional distress and asked for medical treatment, which she did not receive. After her release, she required hospitalization for mental health care. Harris later filed a lawsuit, claiming the city’s failure to train its officers on how to respond to medical needs violated her constitutional rights.
The Court’s Decision
The Supreme Court ruled that municipalities can be held liable under 42 U.S.C. § 1983 if their failure to train officers amounts to what is called “deliberate indifference” to the rights of individuals. Importantly, the Court clarified that cities are not automatically responsible for every officer mistake. Instead, liability arises when the agency’s failure to provide adequate training reflects a conscious or reckless disregard for constitutional rights.
Deliberate Indifference Explained
“Deliberate indifference” means that an agency knew—or should have known—that its officers were likely to face recurring situations that required specific training, and yet failed to provide it. Examples might include:
Training on providing medical aid to people in custody
Training on the lawful use of force
Training on recognizing signs of mental health crisis
If the lack of training predictably leads to constitutional violations, the agency can be found deliberately indifferent.
Why This Matters
Canton v. Harris established that law enforcement agencies can’t simply rely on basic or outdated training. They must actively prepare officers for the real-world challenges they will encounter. Failing to do so isn’t just poor management—it can rise to a constitutional violation.
For officers, this case underscores the importance of ongoing training in areas such as medical care, mental health, and use of force. For agencies, it highlights the need to continually evaluate training programs to ensure they meet professional standards and evolving community expectations.
Key Takeaway
Canton v. Harris reminds us that protecting constitutional rights isn’t only about the decisions made in the field—it’s also about the systems, policies, and training that shape those decisions. When training falls short, agencies risk not only lawsuits but also the trust of the communities they serve.
