Connick v. Thompson
131 S. Ct. 1350
| SCOTUS | 2011Background
- Thompson was convicted of armed robbery and murder after Brady evidence was not disclosed, leading to 18 years in prison and death-row time.
- A crime-lab report showed the blood on the swatch was type B, not Thompson's type O, exculpating him for the robbery charge.
- Prosecutors withheld the lab report and swatch from Thompson in the armed robbery trial and did not disclose it in the murder trial.
- Thompson’s murder trial proceeded with him not testifying, aided by the defeat of the robbery conviction to impeach credibility.
- After discovery in 1999, Thompson’s murder conviction was reversed and retried; he was acquitted on retrial in 2003.
- Thompson sued Connick and the District Attorney’s Office under 42 U.S.C. § 1983 for failure to train prosecutors regarding Brady, seeking damages.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Can a municipality be liable for a single Brady violation under §1983? | Thompson: single violation can show deliberate indifference. | Connick: liability requires a pattern of violations or obvious need for training. | No; single-incident liability not established for Brady training. |
| Is Canton’s single-incident theory applicable to prosecutors’ Brady training? | Dissent argues obvious-need can establish deliberate indifference. | Majority rejects Canton's single-incident rationale for prosecutors. | Not applicable to prosecutors; requires pattern or explicit notice of deficient training. |
| Whether Thompson proved deliberate indifference by Connick to Brady training needs? | Connick was aware Brady issues would arise and training was lacking. | Thompson failed to show Connick knew, with moral certainty, that lack of training would cause the violation. | Thompson failed to prove deliberate indifference. |
| Does lack of Brady-specific training by prosecutors amount to the ‘moving force’ behind Brady violation? | Training gaps caused misapplication of Brady in Thompson’s cases. | The misconduct was due to individual prosecutors’ bad-faith actions, not training gaps. | Cannot establish causation given lack of proof of training-driven causation. |
| Should the jury’s result on deliberate indifference be disturbed given the evidence of Brady violations by multiple prosecutors? | Evidence showed persistent Brady mismanagement across the office. | No basis to infer deliberate indifference without pattern or explicit foreseeability. | Court reversed; no reversible error in disturbing the verdict due to the lack of pattern evidence. |
Key Cases Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution must disclose favorable exculpatory evidence)
- Monell v. New York City Dep’t of Social Servs., 436 U.S. 658 (U.S. 1978) (municipal liability requires official policy or widespread custom)
- Pembaur v. Cincinnati, 475 U.S. 469 (U.S. 1986) (official policy includes acts of policy-making officials and persistent practices)
- Canton v. Harris, 489 U.S. 378 (U.S. 1989) (deliberate indifference standard for failure-to-train claims)
- Bryan County v. Brown, 520 U.S. 397 (U.S. 1997) (pattern of violations ordinarily necessary to prove deliberate indifference)
- Oklahoma City v. Tuttle, 471 U.S. 808 (U.S. 1985) (policy of inadequate training is a high-standard fault for §1983)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (duty to disclose in Brady context; material evidence considerations)
- Arizona v. Youngblood, 488 U.S. 51 (U.S. 1988) (due process considerations for preservation of evidence; good-faith caveat)
- Los Angeles County v. Humphries, 562 U.S. 29 (U.S. 2010) (monell-like causation standard for §1983)