Case: City of Canton v. Harris

5:80-cv-00018 | U.S. District Court for the Northern District of Ohio

Filed Date: Jan. 8, 1980

Closed Date: April 29, 1991

Clearinghouse coding complete

Case Summary

This civil rights case is important doctrinally; the United States Supreme Court clarified the standard under which cities and counties could be liable for constitutional violations that occurred due to failure to train or supervise their employees. On January 8, 1980, Plaintiff, represented by private counsel, filed a 42 U.S.C. § 1983 suit against the City of Canton, Ohio in the United States District Court for the Northern District of Ohio. The plainiff claimed the police violated her rights…

This civil rights case is important doctrinally; the United States Supreme Court clarified the standard under which cities and counties could be liable for constitutional violations that occurred due to failure to train or supervise their employees.

On January 8, 1980, Plaintiff, represented by private counsel, filed a 42 U.S.C. § 1983 suit against the City of Canton, Ohio in the United States District Court for the Northern District of Ohio. The plainiff claimed the police violated her rights when they failed to get her necessary medical attention following arrest.

The 52-year-old plaintiff was arrested for being uncooperative during a traffic stop. When she was brought back for detention, she collapsed repeatedly and acted deliriously. She was left on the floor of the booking facility. After being released, plaintiff suffered a psychiatric episode and required a week of hospitalization. A question of law was certified to the Court of Appeals on the possibility of liability under Monell, and an interlocutory appeal was granted. The U.S. Supreme Court granted certiorari.

In its opinion by Justice White, the United States Supreme Court held that cities and counties could be held liable under Section 1983 for failures to train their officers in the administration of medical care, where that lack of training amounted to deliberate indifference. The Court remanded the case for application of the announced standard. 489 U.S. 378 (1985)

On April 29, 1991, the United States Court for the Northern District of Ohio (Judge Sam Bell) granted summary judgment in favor of the defendants, finding that the lack of training of the officers did not amount to deliberate indifference. The case was closed.

Summary Authors

Blase Kearney (4/9/2012)

People


Judge(s)

Bell, Samuel H. (Ohio)

Jones, Nathaniel Raphael (Ohio)

Lively, Pierce (Kentucky)

Merritt, Gilbert Stroud Jr. (Tennessee)

White, Byron Raymond (District of Columbia)

Attorneys(s) for Plaintiff

Groves, Gregory (Ohio)

Phillips, Carter G (District of Columbia)

Attorneys(s) for Defendant

Albu, Thomas P. (Ohio)

Blomstrom, James L. (Ohio)

Hamann, William J. (Ohio)

Judge(s)

Bell, Samuel H. (Ohio)

Jones, Nathaniel Raphael (Ohio)

Lively, Pierce (Kentucky)

Merritt, Gilbert Stroud Jr. (Tennessee)

White, Byron Raymond (District of Columbia)

Attorneys(s) for Plaintiff

Groves, Gregory (Ohio)

Phillips, Carter G (District of Columbia)

Attorneys(s) for Defendant

Albu, Thomas P. (Ohio)

Blomstrom, James L. (Ohio)

Hamann, William J. (Ohio)

Rudovsky, David (Pennsylvania)

Documents in the Clearinghouse

Document

5:80-cv-00018

Docket

April 29, 1991

April 29, 1991

Docket

85-03314

Order

Harris v. Cmich

U. S. Court of Appeals for the Sixth Circuit

798 F.2d 1414

July 2, 1986

July 2, 1986

Order/Opinion

86-01088

Order (USSC Decision)

City of Canton, Ohio v. Harris

Supreme Court of the United States

489 U.S. 378, 109 S.Ct. 1197, 103 L.Ed.2d 412

Feb. 28, 1989

Feb. 28, 1989

Order/Opinion

Resources

Docket

Last updated Aug. 4, 2022, 3:13 a.m.

ECF Number Description Date Link Date / Link
1

COMPLAINT. (Summons(es), magistrate consent form issued) (R,J A) (Entered: 10/31/1990)

Jan. 8, 1980

Jan. 8, 1980

4

ANSWER to Complaint by all defendants. (R,J A) (Entered: 10/31/1990)

Jan. 22, 1980

Jan. 22, 1980

5

RETURN OF SERVICE re: summ executed upon defendant City of Canton, Stanley Cmich, Canton Police Dept, David Maser Raymond Samolia, James R. Schnabel, Mike Norcia, J. Dianu &Robert Kuehner all on 1/9/80. Fees: $27.00. (R,J A) (Entered: 10/31/1990)

Jan. 30, 1980

Jan. 30, 1980

140

MOTION by defendant City of Canton for summary judgment w/brf &exhs. (78 pgs) (R,J A) (Entered: 10/31/1990)

Oct. 16, 1989

Oct. 16, 1989

141

MOTION by plaintiffs partial for summary judgment . (28 pgs) (R,J A) (Entered: 10/31/1990)

Nov. 13, 1989

Nov. 13, 1989

141

MEMORANDUM by plaintiff in opposition to motion for summary judgment [140−1]. (R,J A) (Entered: 10/31/1990)

Nov. 13, 1989

Nov. 13, 1989

144

REPLY by defendant re [141−1] &in opp to mot for partial SJ w/exh. (50 pgs) (R,J A) (Entered: 10/31/1990)

Dec. 14, 1989

Dec. 14, 1989

145

ORDER holding deft's mot for SJ in abeyance; discovery to be complete 3/15/91; brfs to be complete 4/5/91 . (issued on 1/10/91) (13 pgs) Judge Sam H. Bell (R,J A) (Entered: 01/10/1991)

Jan. 9, 1991

Jan. 9, 1991

146

NOTICE by defendant Canton, City of of ans pla's req for prodctn of docmts &interr (1 pgs) (M,P) (Entered: 03/01/1991)

Feb. 28, 1991

Feb. 28, 1991

147

MEMORANDUM by plaintiff in support of motion partial for summary judgment [141−1]. (14 pgs) (R,J A) (Entered: 04/08/1991)

April 4, 1991

April 4, 1991

147

MEMORANDUM by plaintiff in opposition to motion for summary judgment [140−1]. (R,J A) (Entered: 04/08/1991)

April 4, 1991

April 4, 1991

148

ORDER granting defts' motion for summary judgment [140−1]. terminating case (issued on 5/1/91) (4 pgs) Judge Sam H. Bell (R,J A) (Entered: 05/01/1991)

April 29, 1991

April 29, 1991

149

ORDER that purs to F.R.Cv.P. 58, this action is terminated. terminating case (issued on 5/1/91) (1 pg) Judge Sam H. Bell (R,J A) (Entered: 05/01/1991)

April 29, 1991

April 29, 1991

Case Details

State / Territory: Ohio

Case Type(s):

Jail Conditions

Key Dates

Filing Date: Jan. 8, 1980

Closing Date: April 29, 1991

Case Ongoing: No

Plaintiffs

Plaintiff Description:

A woman arrested for a minor offense who suffered injury because of failure to give medical attention during detention.

Plaintiff Type(s):

Private Plaintiff

Attorney Organizations:

ACLU National (all projects)

Public Interest Lawyer: Yes

Filed Pro Se: No

Class Action Sought: No

Class Action Outcome: Not sought

Defendants

City of Canton (Canton), City

Case Details

Causes of Action:

42 U.S.C. § 1983

Constitutional Clause(s):

Cruel and Unusual Punishment

Due Process

Equal Protection

Unreasonable search and seizure

Availably Documents:

Trial Court Docket

Any published opinion

U.S. Supreme Court merits opinion

Outcome

Prevailing Party: Defendant

Nature of Relief:

None

Source of Relief:

None

Issues

General:

Personal injury

Staff (number, training, qualifications, wages)

Affected Gender:

Female

Medical/Mental Health:

Medical care, general

Mental health care, general

Type of Facility:

Government-run