Prosecutor training and liability
Harry F. Connick v. Thompson
In brief
The Supreme Court overturned the appeals court and ruled that one prosecutor’s failure to disclose favorable evidence was not enough to make the district attorney’s office liable for inadequate training under federal civil-rights law.
- Where it stands
- Decided
Decided 5-4 · March 29, 2011 · Opinion by Justice Thomas
- What it’s about
- John Thompson sued the Orleans Parish District Attorney’s Office after a prosecutor failed to disclose evidence favorable to his defense, arguing that inadequate training made the office responsible.
- Who it affects
- A prosecutor’s office cannot be held liable under federal civil-rights law for inadequate training based on one prosecutor’s failure to disclose favorable evidence.
Summary: written with AI from the case record.
What it's about
The Supreme Court overturned the appeals court, ruling that the office could not be held liable under this failure-to-train theory based on a single violation.
Justice Ginsburg wrote that Thompson spent 18 years in prison, 14 of them on death row, before his innocence of an attempted-robbery charge came to light.
A Supreme Court rule requires prosecutors to disclose evidence favorable to the accused when it is important to guilt or punishment.
Question presented
Can a prosecutor's office be held liable for the illegal conduct of one of its prosecutors, on the theory that the office failed to adequately train its employees, when there has been only one violation resulting from that deficient training?
What the Court decided
Holding
A district attorney’s office may not be held liable under §1983 for failure to train its prosecutors based on a single Brady violation. 578 F. 3d 293, reversed.
- Result
- Reversed
The vote
From the opinions
“The evidence presented to the jury that awarded compensation to Thompson, however, points distinctly away from the Court’s assessment.”
What's next
Lower courts must apply the rule to claims based on a single failure to disclose favorable evidence; the decision does not specify another step in Thompson’s case.
Documents
Opinions
Audio
Docket activity
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AI analysis generated: Impact Analysis
AI analysis generated: Opinion Summary
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AI analysis generated: Decision Record
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Audio Recording added: Oral Arguments - Connick
Opinion added: Connick
More questions
- Did the parties agree evidence was withheld?
- Justice Ginsburg’s opinion says both sides agreed that the prosecution failed to disclose evidence favorable to Thompson.
- Why did Justice Ginsburg disagree?
- She said the trial evidence pointed away from the Court’s view that Thompson had shown only an isolated disclosure violation.
- What did Justice Scalia emphasize?
- He framed the issue as whether the need for training was so obvious that failing to provide it could make the office responsible, even without a pattern of earlier violations.
Sources
Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.