Jones v. Town of East Haven
691 F.3d 72
| 1st Cir. | 2012Background
- Jones shot and killed by East Haven Officer Flodquist in 1997; Emma Jones sues Town, Flodquist, and DePalma under §1983 for constitutional violations.
- Plaintiff contends Town had a custom, policy, or usage of deliberate indifference to the rights of black people.
- Jury found the officers liable but Town liable overall; district court denied the Town’s Rule 50 motion.
- Appellate court holds plaintiff’s evidence insufficient to establish Monell liability and reverses in favor of Town.
- Court outlines Monell standards, deliberate indifference, and need for supervisory awareness or action.
- Case remanded with instructions to enter judgment for the Town; district court to vacate Plaintiff’s judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is there sufficient Monell liability evidence? | Jones argues Town’s pattern of abuse shows deliberate indifference. | Town contends evidence fails to show widespread custom or supervisory tolerance. | Insufficient evidence to support Monell liability. |
| Do the six incidents establish a municipal policy or custom? | Aggregate incidents show persistent abuse by officers. | Incidents are isolated and not tied to Town policy or deliberate indifference. | Not enough to infer a Town policy or custom. |
| Was the district court correct to deny JMOL under Rule 50? | Plaintiff asserts sufficient evidence of municipal liability. | Evidence does not meet deliberate indifference standard. | Grant of JMOL for the Town appropriate. |
| What standard governs deliberate indifference in Monell claims? | Policy-makers were aware or should have been aware of abuses. | No evidence of supervisory awareness or inaction showing policy. | Deliberate indifference not proven; Monell liability not established. |
Key Cases Cited
- Monell v. Department of Social Services, 436 U.S. 658 (1978) (establishes municipal liability via custom or policy; moving force requirement)
- Connick v. Thompson, 131 S. Ct. 1350 (2011) (municipal liability for persistent, widespread practices; policy/indifference)
- Brown v. Bresnahan?, 520 U.S. 397 (1997) (deliberate indifference standard; notice and inaction for constitutional violations)
- City of Canton v. Harris, 489 U.S. 378 (1989) (policy-maker disregard of risk; deliberate indifference through inaction)
- Amnesty Am. v. Town of West Hartford, 361 F.3d 111 (2d Cir. 2004) (2004) (deliberate indifference can be shown where supervisors tolerate abuse)
- Tennessee v. Garner, 471 U.S. 1 (1985) (use of force where suspect poses danger; warnings may be feasible)
- Cash v. County of Erie, 654 F.3d 324 (2011) (deliberate choice required, not mere negligence)
- Nimely v. City of New York, 414 F.3d 381 (2005) (standard for reviewing Rule 50 denial in §1983 cases)