Connick v. Thompson
Issues
Is a single failure by prosecutors to provide exculpatory evidence to a defendant sufficient to establish failure-to-train liability against a District Attorney’s office?
John Thompson was wrongfully imprisoned for 18 years following a trial during which the prosecutor withheld exculpatory evidence, in violation of Brady v. Maryland. Thompson brought suit pursuant to 42 U.S.C. § 1983 alleging that the district attorney's office is liable for failing to properly train its employees on the requirements of Brady. The U.S. Court of Appeals for the Fifth Circuit found in favor of assigning liability to the district attorney's office. Petitioners, including District Attorney Harry Connick, appealed to the Supreme Court. Connick claims that there was no obvious need to train prosecutors regarding Brady standards and that liability should not attach to the office when there was no notice that the training program needed reform. Respondent Thompson contends that the prosecutors’ lack of training amounted to a deliberate indifference to preserving constitutional rights and that liability may properly attach to the district attorney's office without a past history of violations. This decision will determine the extent to which a municipality may be liable for a single action by one of its employees.
Questions as Framed for the Court by the Parties
Does imposing failure-to-train liability on a district attorney's office for a single Brady violation contravene the rigorous culpability and causation standards of Canton and Bryan County?
In April 1985, shortly before his murder trial, a Louisiana state court convicted Respondent John Thompson of attempted armed robbery. See Thompson v. Connick, 578 F.3d 293, 296 (5th Cir. 2009). Several weeks later in May 1985, the same court convicted Thompson of first-degree murder and sentenced him to death. See Thompson v. Connick, 2007 U.S. Dist. Lexis 29717 at *2 (E.D. La.
Edited by
Additional Resources
· Wex: Brady Rule
· Law.com, Tony Mauro: Clement Lines Up Ex-Prosecutors, Seeks Argument Time in Misconduct Case (Aug. 25, 2010)
· New Orleans Times-Picayune, Katy Reckdahl: Appeals Court Upholds $14 Million Judgment Against Orleans DA Office (Dec. 20, 2008)