connick v thompson case study

Posted on October 8th, 2020

investigated discovered lab report and found blood did not not match thompsons.

, 9 The dissent defers consideration of this question until page 23 of its opinion. In Canton versus Harris, this Court left open the possibility that failure to train liability could be based on a single incident when the need for training was patently obvious such as when a city does not tell police officers about the constitutional limits on the use of deadly force. See Brady v. Maryland, 373 U. S. 83 (1963).

Thompson also asserts that this case is not about a “single incident” because up to four prosecutors may have been responsible for the nondisclosure of the crime lab report and, according to his allegations, withheld additional evidence in his armed robbery and murder trials. The text is used in a class on ethics and tactics for the criminal lawyer at Harvard Law School and in the federal defender training program of the Administrative Office of the United States Courts. However, Connick suppressed a critical blood sample test. But training must consist of more than mere broad encomiums of Brady: We have made clear that “the identified deficiency in a city’s training program [must be] closely related to the ultimate injury.” Canton, supra, at 391. Perhaps a better question to ask is what legally accurate training would have prevented it. , 520 U. S., at 410.

The role of a prosecutor is to see that justice is done.

While Thompson was in prison, his investigator discovered a crime report from his robbery case.

would have been helpful.” 553 F. 3d, at 854.

’s requirements; (3) Cf. A less stringent standard of fault for a failure-to-train claim “would result in de facto respondeat superior liability on municipalities … .” Id., at 392; see also Pembaur, supra, at 483 (opinion of Brennan, J.) And when they did occur, Connick insisted there was no need to change anything, and opposed efforts to hold prosecutors accountable on the ground that doing so would make his job more difficult.

See also id., at 1096–1097, 1099–1100.

Held: A district attorney’s office may not be held liable under §1983 for failure to train its prosecutors based on a single Brady violation.

Connick explained to the jury that prosecutors’ offices must “make … very clear to [new prosecutors] what their responsibility [i]s” under Brady and must not “giv[e] them a lot of leeway.” Tr. Armed with the later indictment against Thompson for robbery, however, the prosecutors made a strategic choice: They switched the order of the two trials, proceeding first on the robbery indictment. He asks only that Brady obligations be communicated accurately and genuinely enforced.

In late April 1999, Thompson’s private investigator discovered the crime lab report from the armed robbery investigation in the files of the New Orleans Police Crime Laboratory.

Stat. And that this lack of training had caused the prosecutor's failure to disclose a lab report in his case. Second, Connick confessed to having withheld a crime lab report “one time as a prosecutor and I got indicted by the U. S. Attorney over here for doing it.” Id., at 872.

, 41. Post, at 16. Riehlmann thereupon told Whittaker that Deegan “had failed to turn over stuff that might have been exculpatory.” Tr. 7/17/02), 825 So. We conclude that this case does not fall within the narrow range of “single-incident” liability hypothesized in In addition, attorneys in all jurisdictions must satisfy character and fitness standards to receive a law license and are personally subject to an ethical regime designed to reinforce the profession’s standards. Further, a prosecutor should not intentionally avoid pursuit of evidence merely because he believes it will damage the prosecution’s case or aid the accused.” LSBA, Articles of Incorporation, Art. See supra, at 13.

Pembaur In finding two of the “new” violations, the dissent belatedly tries to reverse the Court of Appeals’ 1998 decision that those Brady claims were “without merit.” Compare Thompson v. Cain, 161 F. 3d 802, 806–808 (CA5) (rejecting Brady claims regarding the Perkins-Liuzza audiotapes and the Perkins police report), with post, at 8–9 (concluding that these were Brady violations). Third, Connick’s cavalier approach to his staff’s knowledge and observation of Brady requirements contributed to a culture of inattention to Brady in Orleans Parish. In late April 1999, Thompson’s private investigator discovered the crime lab report from the armed robbery investigation in the files of the New Orleans Police Crime Laboratory. 834–835. (4) The Office shirked its responsibility to keep prosecutors abreast of relevant legal developments concerning Brady requirements.

Thus, Thompson cannot rely on the lack of an ability to cope with constitutional situations that underlies the Canton hypothetical, but must assert that prosecutors were not trained about particular Brady evidence or the specific scenario related to the violation in his case.

The deliberate indifference jury instruction in this case was based on the Second Circuit’s opinion in Walker v. New York, 974 F. 2d 293, 297–298 (1992), applying Canton to a §1983 complaint alleging that a district attorney failed to train prosecutors about Brady. Id., at 1585; see Kyles v. Whitley, 514 U. S. 419, 421 (1995) (“[T]he state’s obligation under Brady … turns on the cumulative effect of all … evidence suppressed by the government … .”). In 1994, nine years after Thompson’s convictions, Deegan, the assistant prosecutor in the armed robbery trial, learned he was terminally ill.

The dissent does not list these violations among the “[a]bundant evidence” that it believes supports the jury’s finding that Brady training was obviously necessary. 46. Record EX151, EX589. 6 But, as reams of evidence showed, disregard of Brady occurred, over and over again in Orleans Parish, before, during, and after Thompson’s 1985 robbery and murder trials.

to micromanage local governments throughout the United States. That man, the government’s key witness at the first murder trial, had died in the interval between the first and second trials. See post, at 12, n. 10, 15, n. 11. 719. Attorneys are trained in the law and equipped with the tools to interpret and apply legal principles, understand constitutional limits, and exercise legal judgment. ", "(b) A pattern of similar constitutional violations by untrained employees is “ordinarily necessary” to demonstrate deliberate indifference. Brief for Respondent 37. liability on municipalities … .” The dissent rejects our holding that Canton’s hypothesized single-incident liability does not, as a legal matter, encompass failure to train prosecutors in their Brady obligation.

[Footnote 6].

Bryan Cty., supra, at 409. Bryan Cty. None of those cases involved failure to disclose blood evidence, a crime lab report, or physical or scientific evidence of any kind.

Get Connick v. Thompson, 563 U.S. 51 (2011), United States Supreme Court, case facts, key issues, and holdings and reasonings online today.

of Oral Arg. own 872.

436 U. S. 658, Bryan County de facto respondeat superior v. But Connick acknowledged that he had “stopped reading law books … and looking at opinions” when he was first elected District Attorney in 1974.

See Tr. A district attorney's office therefore may not be held liable under Section 1983 for failure to train based on a single Brady violation. See Cone v. Bell, 556 U. S. ___, ___ (2009) (slip op., at 1).

of those claims, made on an anemic record, in Thompson v. Cain, 161 F. 3d 802.

Thompson's murder conviction was also reversed on the ground that the armed robbery conviction had unconstitutionally deprived him of the right to testify in his own defense at his murder trial. (“Or Connick could have told prosecutors what he told the jury when he was asked whether a prosecutor must disclose a crime lab report to the defense, even if the pros-ecutor does not know the defendant’s blood type: ‘Under the law, it qualifies as Brady material.’ ” (quoting Tr.

Relying on

Indicting Thompson on the basis of these questionable identifications, the District Attorney’s Office did not pause to test the pant leg swatch dyed by the perpetrator’s blood.

But cf. ibid.

Board of Comm’rs of Bryan Cty. , 489 U. S., at 391. Bryan County 15, §§5, 6 (1971); The evidence in this case presents overwhelming support for the conclusion that the Orleans Parish Office slighted its responsibility to the profession and to the State’s system of justice by providing no on-the-job Brady training. Attorneys who practice with other attorneys, such as in district attorney’s offices, also train on the job as they learn from more experienced attorneys. , at 30–31 (describing our reliance on 16 (1971) (Code of Professional Responsibility). These threshold requirements are designed to ensure that all new attorneys have learned how to find, understand, and apply legal rules.

And he testified in the §1983 action that the lab report was not Brady material “because I didn’t know what the blood type of Mr. Thompson was.” Tr.

This lapse ignored or overlooked a prosecutor’s notation that the Office “may wish to do [a] blood test.” Id., at EX122. 4, App., Art. 986; cf. (2) Other leaders in the Office, who bore direct responsibility for training less experienced prosecutors, were similarly uninformed about Brady. The newly produced items included police reports describing the assailant in the murder case as having “close cut” hair, the police report recounting Perkins’ meetings with the Liuzza family, see supra, at 3–4, audio recordings of those meetings, and a 35-page supplemental police report. In protest, that prosecutor tendered his resignation. A few weeks later, Williams and special prosecutor Eric Dubelier tried Thompson for the Liuzza murder. ). and the Court of Appeals for the Fifth Circuit affirmed by an evenly divided en banc court. Because those incidents are not similar to the violation at issue here, they could not have put Connick on notice that specific training was necessary to avoid this constitutional violation. Second, “the situation involved a difficult choice[,] or one that prosecutors had a history of mishandling, such that additional training, supervision or monitoring was clearly needed.” Ibid.

2d 552.

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