Connick v. Thompson
563 U.S. 51
SCOTUS2011Background
- Thompson was convicted of armed robbery; a crime lab report and blood-type evidence, which could have aided Thompson, were never disclosed by prosecutors.
- A separate Liuzza murder trial followed; Thompson did not testify because of the earlier armed robbery conviction.
- Evidence later revealed the blood on the swatch belonged to someone other than Thompson, undermining the robbery conviction and prompting retrial for the murder; Thompson was acquitted in the retrial.
- Thompson sued Connick and the District Attorney’s Office under 42 U.S.C. § 1983 for failure to train prosecutors about Brady obligations, claiming deliberate indifference caused the Brady violation.
- A jury found liability based on a theory that the office’s failure to train prosecutors amountd to deliberate indifference; the district court and Fifth Circuit affirmed.
- The Supreme Court reversed, holding that a municipality cannot be liable under § 1983 for a single Brady violation absent a pattern of prior violations or proof of deliberate indifference to a known need for training.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a municipality can be liable for a single Brady violation | Thompson | Connick | No; single-incident liability not enough |
| Whether Canton’s single-incident theory applies to prosecutors’ Brady training | Thompson | Connick | Not applicable; narrow Canton exception rejected |
| Whether Thompson proved deliberate indifference to the need for Brady training | Thompson | Connick | No; insufficient evidence of obvious training deficiency |
| Whether causation was shown between training failure and the Brady violation | Thompson | Connick | Not reached; decision on liability based on lack of deliberate indifference |
Key Cases Cited
- Monell v. New York City Dept. of Social Services, 436 U.S. 658 (U.S. 1978) (establishes municipal liability requires official policy or practice)
- Canton v. Harris, 489 U.S. 378 (U.S. 1989) (deliberate indifference standard for failure-to-train claims; narrow exceptions)
- Bryan County v. Brown, 520 U.S. 397 (U.S. 1997) (pattern of violations ordinarily necessary for failure-to-train liability)
- Pembaur v. Cincinnati, 475 U.S. 469 (U.S. 1986) (Monell-like ideas of official policy and deliberate action)
- Kyles v. Whitley, 514 U.S. 419 (U.S. 1995) (cumulative Brady evidence rule; duty to disclose favorable material)
- United States v. Bagley, 473 U.S. 667 (U.S. 1985) (Brady material includes impeachment and exculpatory evidence)