Connick v. Thompson
Citation and Court
563 U.S. 51 (2011), Supreme Court of the United States
Facts
John Thompson spent 18 years on death row after prosecutors in New Orleans failed to disclose blood evidence that would have exculpated him in a robbery case — a conviction used to keep him from testifying in his own murder trial. One month before his execution, the evidence was discovered. After his convictions were overturned, Thompson sued the district attorney’s office under 42 U.S.C. § 1983, arguing the office had a policy or custom of Brady violations.
Issue
Whether a district attorney’s office can be held liable under § 1983 for a single Brady violation by one of its prosecutors under a failure-to-train theory.
Holding
A single Brady violation is insufficient to establish the deliberate indifference required for municipal liability under Monell v. Department of Social Services; a pattern of similar violations is necessary to impose § 1983 liability on the prosecutor’s office.
Rule / Doctrine
Under Monell, a municipality (including a prosecutor’s office) is liable under § 1983 only when an official policy or custom causes a constitutional deprivation. A failure-to-train theory requires showing deliberate indifference, which ordinarily requires a pattern of similar constitutional violations. A single incident generally cannot establish deliberate indifference.
Significance
Connick significantly limits civil accountability for Brady violations by prosecutor’s offices. It makes systemic § 1983 suits against DA offices very difficult and has been criticized as leaving defendants without an adequate remedy for prosecutorial misconduct. The case is frequently taught alongside Brady v. Maryland to underscore the gap between the constitutional right and its enforcement.