42 U.S.C. § 1983

Section 1983 permits county liability for inadequate training or supervision when the failure shows deliberate indifference to constitutional rights.

Otani v. City and County of Haw. · filed 1998-06-05

Plaintiff is correct in asserting that the County can be held liable under Section 1983 for its failure to properly supervise or train its employees where such failure evidences a deliberate indifference to the constitutional rights of Plaintiff.

A § 1983 claim against a county or sheriff for failure to train or supervise requires evidence of deliberate indifference to constitutional rights or authorization of unconstitutional conduct.

Hoover v. McDowell County · filed 1998-06-15

Hoover failed to present any evidence establishing that McDowell County and Sheriff Hanes were deliberately indifferent to the constitutional rights of its citizens or that they authorized unconstitutional behavior.

Section 1983 liability for inadequate policy, training, or supervision requires notice of the inadequacy followed by a failure to act.

Parish v. Hill · filed 1998-07-21

Liability will not be imposed under this standard absent a showing that a defendant had been put on notice that a particular policy, training technique, or method of supervision was inadequate, and yet, failed to take action. ... Accordingly, we hold that summary judgment was properly granted for defendants Biggs and the City of Hillsborough on plaintiff’s § 1983 claim.

Section 1983 does not automatically make a municipality liable for officers’ constitutional violations even if its training or supervision was inadequate.

Gold v. City of Miami · filed 1998-08-27

Thus, the City is not automatically liable under section 1983 even if it inadequately trained or supervised its police officers and those officers violated Gold's constitutional rights.

Section 1983 does not impose municipal liability for failure to train or supervise without notice of a need for training or supervision in the particular area.

Gold v. City of Miami · filed 1998-08-27

This Court repeatedly has held that without notice of a need to train or supervise in a particular area, a municipality is not liable as a matter of law for any failure to train and supervise.

A Section 1983 claim against a municipality for inadequate police training or supervision can survive summary judgment when the municipality fails to establish the relevant facts.

Clark v. City of Norwalk, No. X01 Cv 93 0146667 (Dec. 10, 1998) · filed 1998-12-10

In addition to their common law claims, the plaintiffs have asserted that the City of Norwalk violated their constitutional rights by failing to train and supervise its police officers adequately and appropriately. ... The City has failed to show what the facts are with regard to the adequacy of training and supervision, and has therefore failed to establish that it is entitled to judgment on the constitutional claims based on those allegations.

Section 1983 requires a constitutional violation and facts establishing a custom of inadequate training or supervision for municipal failure-to-train liability.

Ellis v. City of Lindsay · filed 1998-12-17

Our conclusion that the use of force was not excessive and therefore no constitutional violation occurred stands. Even if the force was unreasonable or conscience shocking, plaintiff failed to set forth any facts establishing either a custom of inadequate training or supervision.

Section 1983 failure-to-train liability requires a cognizable injury, an inadequate-training policy or custom, a direct causal link to the constitutional violation, and deliberate indifference.

Hedges v. Musco · filed 1999-01-26

To hold the members of the NHRHS Board of Education liable on a failure to train theory under § 1983, Plaintiffs must establish that: (1) Nurse Kiely, Mr. McDonald or Mr. Musco inflicted a cognizable injury on Tara; (2) Nurse Kiely, Mr. McDonald or Mr. Museo acted pursuant to a NHRHS Board of Education custom or policy not to adequately train or supervise its employees; (3) there is a direct causal link between the custom or policy and the alleged constitutional violation; and (4) the failure to so train or supervise amounts to deliberate indifference to the rights of the NHRHS pupils.

Section 1983 permits municipal liability for failure to train or supervise when that failure reflects deliberate indifference to constitutional rights.

Soltis v. Kotenski · filed 1999-07-09

Failure to train and properly supervise employees “in deliberate indifference” to the rights of its inhabitants establishes a municipal custom or policy actionable under Section 1983.

Section 1983 permits a failure-to-instruct claim when the failure shows deliberate indifference to citizens’ constitutional rights.

Pena, Marilyn v. Leombruni, Greg · filed 1999-12-30

A failure to instruct police officers can, it is true, exhibit a deliberate indifference to the danger that armed police can pose to the constitutional rights of citizens and if it does is actionable under 42 U.S.C. sec. 1983.

Section 1983 requires a causal link between a sheriff’s failure to train or supervise deputies and harm from an arrest; probable cause for the arrest defeats that claim.

Ryan v. Worch · filed 2000-04-26

Where the complaint itself reveals probable cause to arrest, there can be no cause of action for failure to train. This is because probable cause to arrest destroys any possible link between any alleged failure of appellee to properly train and supervise his deputies and any resulting harm to appellant for his arrest based on probable cause.

Section 1983 does not permit failure-to-train or failure-to-supervise liability when the officer committed no underlying constitutional violation.

Neal v. St. Louis County Board of Police Commissioners · filed 2000-07-03

Because Peterson did not violate Neal's Fourteenth Amendment rights, the County and City Official defendants cannot be held liable for a failure to train or supervise Officer Peterson.

Section 1983 requires a plaintiff alleging inadequate municipal training or supervision to show inadequate procedures, deliberate indifference in adopting them, and a direct causal link to the injury.

Hover v. Brenner · filed 2000-08-11

To succeed on such claims, Hover must show that the training and supervision procedures of the municipality’s policymaker were inadequate, that the municipality was deliberately indifferent in adopting those procedures, and that the inadequate procedures directly caused the plaintiff’s injury.

A § 1983 claim based on a municipality's failure to train or supervise requires facts supporting deliberate indifference; alleging deliberate indifference alone is insufficient.

Doe v. Klingberg Family Centers, No. Cv 00 504520 (Aug. 15, 2001) · filed 2001-08-15

The plaintiff in the present case has not made sufficient factual allegations to support the three requirements of Walker . Although her complaint alleges deliberate indifference on the part of the board of education; (see Complaint, count 12, ¶ 22); the plaintiff did not plead any facts to support that legal conclusion.

Section 1983 failure-to-train supervisory liability requires proof that the failure constituted deliberate indifference to the plaintiff’s constitutional rights; one expert’s testimony alone was insufficient to establish it.

Cozzo v. Tangipahoa Parish Council-President Government · filed 2001-09-05

Even taking the evidence in the light most favorable to the jury’s verdict that Sheriff Layrisson’s failure to train Deputy Joiner actually caused Ms. Cozzo’s injury, Ms. Cozzo still bore the onus to prove that this failure to train constituted deliberate indifference to her right not to be unconstitutionally dispossessed of her property. Kent’s testimony alone is, however, insufficient to meet this burden.

Section 1983 does not support a failure-to-train or supervise claim against a governmental employer when no employee violated the plaintiff’s constitutional rights.

Scott v. Michigan · filed 2001-11-14

This Court’s conclusion that no officer-defendant deprived Plaintiffs of their substantive due process rights likewise defeats Plaintiffs’ claims against the employer/supervisor of these Defendants.

Section 1983 liability for a municipality’s failure to train or supervise requires proof that the municipality was deliberately indifferent to or tacitly authorized misconduct and that its custom caused the constitutional violation.

Vickowski v. Hukowicz · filed 2002-03-13

Still, even assuming Hadley had notice of Hukowicz’s alleged abuse, it is Plaintiffs burden to show that the town “remained deliberately indifferent to or tacitly authorized continuation of that misconduct” and that it was “the moving force behind the violation.” Armstrong, 938 F.Supp. at 1036. Plaintiff fails in this regard as well.

A § 1983 claim for failure to train or supervise officers requires an underlying constitutional violation by those officers.

Caricofe v. Mayor and City Cncl · filed 2002-04-01

Because the police officers did not violate Caricofe’s constitutional rights, the other defendants may not be held liable for failing to train or supervise those officers.

A § 1983 claim against a city for failure to train or supervise requires evidence of deliberate indifference; one mishandled case does not establish a pattern or practice.

Hansell v. City of Atlantic City · filed 2002-08-22

This one case fails to show a pattern or practice of ignoring domestic violence complaints against police officers. Although we are concerned as to how acts of domestic violence by police officers are treated by the Police Department, plaintiffs have not shown that the City of Atlantic City displayed “ ‘deliberate indifference’ to the rights of persons with whom [its] employees will come into contact,” namely, victims of acts of domestic violence by police officers.

A supervisor’s failure to train supports § 1983 liability only when the evidence shows an obvious need for additional training.

Doe v. Gustavus · filed 2003-08-29

But even apart from the inconsistencies noted above, the evidence presented here against Meier is insufficient to support the plaintiffs failure to train theory of deliberate indifference. Prior to the incident giving rise to this suit,-there is simply no evidence that additional training was an obvious need.

Section 1983 permits county liability for failure to train or supervise law enforcement officers when that failure is grossly negligent enough to constitute deliberate indifference.

Owens v. Haas · filed 1979-07-09

It is true that the failure to train or supervise law enforcement officers must be so grossly negligent as to constitute "deliberate indifference" in order to hold the county liable.

Section 1983 permits supervisory liability for failure to train only when the supervisor had reason to know that a subordinate was highly likely to cause the particular injury suffered.

Christopher v. Nestlerode · filed 2005-06-22

In other words, only when the supervisor had reason to know that the subordinate "was highly likely to inflict the particular injury suffered by the plaintiff" may the supervisor be held liable under § 1983.

Section 1983 requires evidence of a department custom or policy of inadequate training or supervision to support a claim based on that practice.

Granlund v. Clark · filed 2005-08-10

The evidence the Granlunds presented does not create a genuine issue of material fact as to whether the Sheriffs Department had a custom or policy of failing adequately to train or to supervise Deputy Clark.

Section 1983 permits supervisory liability for inadequate training when a specific training deficiency caused the constitutional violation and an affirmative link connects the supervisor to it.

Gaston v. Ploeger · filed 2005-11-17

To the extent that Plaintiff argues Shoemaker failed to adequately train jail personnel, Plaintiff (1) must identify a specific deficiency in Shoemaker’s training that is closely related to Belden’s ultimate injury; and (2) must prove that the deficiency in training actually caused jail personnel to act with deliberate indifference to Belden’s safety. In this case, the Court finds Plaintiff has presented sufficient evidence that a jury could find an affirmative link between the constitutional deprivation alleged and Shoemaker’s training practices and general exercise of control over the jail.

Section 1983 does not impose liability for failure to supervise or train when the underlying conduct states no viable constitutional claim.

Smith v. Busby · filed 2006-02-14

Plaintiffs therefore cannot establish section 1983 liability for failure to supervise or train, see McCoy v. City of Monticello, 411 F.3d 920, 922-23 (8th Cir. 2005), and we need not address the issue of qualified immunity, see Crumley v. City of St. Paul, 324 F.3d 1003, 1008 (8th Cir. 2003).

Section 1983 municipal liability for inadequate police training or supervision requires evidence that official policymakers knew or should have known of the deficient policy and were deliberately indifferent to constitutional rights.

Jones v. Pillow · filed 2006-06-22

Furthermore, he offers no evidence that the City’s official policy makers were actually or constructively aware of a policy against adequately training and supervising, such that they were deliberately indifferent towards the constitutional rights of persons who came into contact with the police. Accordingly, Jones has failed to establish a genuine issue of fact material to his claim for municipal liability.

Section 1983 requires a plaintiff alleging municipal failure to train or supervise to show that the municipality was deliberately indifferent and that its policy or custom caused the injury.

Ellis v. Cleveland Municipal · filed 2006-07-24

Pendergrass’s claim of failure to train or supervise nonetheless fails because no reasonable jury could find that the School District was deliberately indifferent to complaints of abuse by substitute teachers. A plaintiff who sues a municipality for a constitutional violation under § 1983 must prove that the municipality’s policy or custom caused the alleged injury.

A § 1983 claim that a municipality failed to train or supervise requires evidence that it was deliberately indifferent to a need for additional training or supervision.

Udine Ellis, Guardian for Lateasha Pendergrass v. Cleveland Municipal School District · filed 2006-07-24

Similarly, because Pendergrass has not presented any evidence that two incidents of substitute-teacher abuse is more than what the normal number of incidents would be, she cannot show that the School District had notice of a problem requiring additional training or supervision. Thus, as a matter of law, her claim of failure to train or supervise fails because a reasonable jury could not find the School District deliberately indifferent.

Section 1983 requires deliberate indifference for municipal liability based on a failure to train or supervise.

Whitewater v. Goss · filed 2006-08-23

These claims fail because Plaintiffs have not shown that Sheriff Goss acted with the requisite deliberate indifference— a necessary element to a failure-to-train or failure-to-supervise claim.

Section 1983 does not impose supervisory liability for failure to train jail staff when the record does not show an obvious need for additional training or a substantial risk that staff would disregard inmates’ medical needs.

Williams v. Limestone County Alabama · filed 2006-10-02

Thus, we cannot say, on this record, that “the need for more or different training [was] obvious,” such that by failing to ensure jail personnel were trained in emergency medical procedures, Sheriff Blakely disregarded a substantial risk that the jail staff would be deliberately indifferent to inmates’ medical needs.

Section 1983 permits a claim against a village and its police department when the complaint alleges deliberate indifference to constitutional rights through inadequate training and supervision of officers.

Watkins v. Village of Briarcliff Manor · filed 2006-10-17

Giving the allegations of the complaint the benefit of every favorable inference (see Leon v Martinez, 84 NY2d 83, 87-88 [1994]; CPLR 3211 [a] [7]), we conclude that the complaint states a cause of action pursuant to 42 USC § 1983 for violation of the plaintiffs civil rights against the defendants Village of Briarcliff Manor and Briarcliff Manor Police Department, insofar as it alleges that those defendants acted with deliberate indifference to the plaintiffs constitutional rights in failing to adequately train and supervise their police officers in matters concerning the sealing of arrest records and dissemination of information from sealed arrest records to the public (see Johnson v Kings County Dist. Attorney’s Off., 308 AD2d 278 [2003]).

Section 1983 requires a plaintiff claiming that a municipality failed to train or supervise its officers to identify a policy or custom showing deliberate indifference to constitutional rights.

Adams v. City of Camden · filed 2006-11-08

The Court will grant the summary judgment motion as to Plaintiffs § 1983 claims against the City for inadequate training or supervision of Officer Acetti and other police officers because Plaintiff has not identified any policy or custom that would establish the City’s conscious disregard for constitutional rights.

Section 1983 requires an underlying constitutional violation to support a claim for failure to train or supervise police officers.

Sanders Sr. v. City of Union Springs · filed 2006-11-15

Again, because plaintiffs are unable to establish a constitutional violation, they are unable to maintain a § 1983 action for failure to train or supervise the City’s officers in high-speed pursuits.

A § 1983 claim against a city for failure to train or supervise requires facts showing that the failure caused a constitutional deprivation.

Jenkins v. City of New York · filed 2007-02-06

Because Jenkins failed to allege facts establishing that any constitutional deprivations he suffered were a consequence of the City’s failure to adequately train or supervise its officers, summary judgment dismissing his section 1983 claim of false arrest against the City was proper.

Section 1983 municipal liability for failure to train or supervise requires evidence of a pervasive policy or custom.

Tafler v. District of Columbia · filed 2008-03-27

To support a finding of municipal liability, a policy or custom must be pervasive.

Section 1983 liability for failure to train or supervise requires notice of prior misconduct and a failure to act that causes injury.

Dick v. Watonwan County · filed 1984-07-11

In order to succeed on this basis, plaintiffs must "establish that [Schutt] had notice of prior misbehavior and that [his] failure to act upon such knowledge caused [their] injury." Herrera v. Valentine, 653 F.2d 1220, 1224 (8th Cir.1981). As stated earlier, this was a first-time incident. There was nothing to indicate that it could happen. Therefore, under our cases no liability can be based on failure to train or supervise.

A § 1983 claim for failure to train or supervise requires an underlying violation of constitutional rights.

Baribeau v. City of Minneapolis · filed 2008-09-12

To prevail on their failure to train and supervise claims, Plaintiffs must establish an underlying violation of their constitutional rights.

Section 1983 does not impose liability on a supervisory official or governmental employer for failure to train or supervise when the employees committed no constitutional violation.

Estate of Harvey Ex Rel. Dent v. Roanoke City Sheriff's Office · filed 2008-11-05

It is well established that there can be no liability under § 1983 on the part of a supervisory official or governmental employer in the absence of a constitutional violation on the part of the employees being supervised.

A municipality cannot be held liable under § 1983 for failure to train or supervise when no such failure occurred.

Brumfield v. Hollins · filed 2008-12-02

As we observed earlier in this opinion, Sheriff Stringer did not fail to train or supervise his subordinates. Without a failure to train or supervise, Brumfield cannot satisfy the first element of municipal liability and, consequently, Marion County cannot be held liable under § 1983.

Section 1983 does not impose supervisory or municipal liability for inadequate police training, supervision, or control based on simple negligence alone.

Donald L. Hays, Jr., and Michael C. Potter, Cross-Appellants v. Jefferson County, Kentucky, Wilbur Bilyeu and Russell Mc · filed 1982-01-04

Because this Court holds that simple negligence is insufficient to support liability of high police officials and municipalities for inadequate training, supervision, and control of individual officers, we must vacate the verdict and remand this matter to the District Court for a new trial.

Section 1983 permits municipal liability for failure to train or supervise only when that failure shows deliberate indifference to constitutional rights.

Sewell v. Town of Lake Hamilton, FL · filed 1997-07-21

Applying the Walker reasoning to the facts of this case, we cannot say that the Town acted or failed to act in such a way as to constitute deliberate indifference.

Section 1983 does not impose municipal liability for employee misconduct alone; a failure-to-train or supervise claim requires a deficient municipal policy or custom adopted with deliberate indifference.

Jacobs v. City of Port Neches · filed 1998-06-04

In summary, merely identifying inappropriate behavior by municipal employees, standing alone, will not support a section 1983 claim against the municipality.

Section 1983 requires proof of deliberate indifference for a supervisory failure-to-train claim; without it, the court need not consider the other elements of supervisory liability.

Goodman v. Harris County · filed 2009-06-10

As Goodman’s § 1983 claim fails because she has not shown deliberate indifference, we need not discuss the remaining prongs of supervisor liability.

Section 1983 requires evidence that a municipality’s deliberate indifference in police training or supervision actually caused the alleged constitutional injury; conclusory assertions do not suffice.

Gross Ex Rel. Spears v. District of Columbia · filed 1999-07-29

The expert’s conclusory assertions, without any detailed explanation of the link in this case, or, e.g., rebanee on studies demonstrating a link between deficiencies in training and supervision and constitutional violations by police officers generally, were insufficient for a reasonable jury to conclude that the District had a pobey of deliberate indifference to training or supervision of its pobce officers that actually caused the alleged brutabty by the unknown officers in this case. Under the exacting standards established by the Supreme Court for municipal babibty under 42 U.S.C. § 1983, we conclude summary judgment was proper here.

Section 1983 requires a plaintiff alleging municipal liability for failure to train or supervise to identify a specific deficiency that caused the constitutional violation.

Hernandez v. Connecticut Court Support Services Division · filed 2009-11-03

Instead, Mr. Hernandez must identify specific aspects of the City’s training program or supervision that were inadequate to the task at hand and which actually caused the constitutional violations.

Section 1983 permits municipal liability when deliberately indifferent training or supervision causes a constitutional violation.

Jones v. City of Brunswick · filed 2010-03-26

A reasonable jury could so conclude. Although the City of Brunswick expressly forbids performing a strip-search of an arrestee absent a particularized reason to do so and implicitly forbids photographing an arrestee in the course of such a search, viewing the facts in the light most favorable to the non-moving party, that is precisely what occurred in this ease, and there is sufficient evidence to allow a reasonable jury to conclude that this occurred because of deliberately indifferent training or supervision.

A Section 1983 claim against a sheriff for inadequate training or supervision fails when the complaint does not state an underlying constitutional violation by jail staff.

Richard W. Troyanos, Jr. v. Coats · filed 2010-04-13

Troyanos’s complaint also fails to allege that Coats was deliberately indifferent because he did not properly train, supervise, or discipline his staff. We are not required to inquire about Coats’s customs or policies for treating mentally ill inmates because the complaint failed to state a claim that jail officials violated Troyanos’s constitutional rights.

Section 1983 failure-to-train and failure-to-supervise claims against a municipality require an underlying constitutional violation by an officer.

Sitzes v. City of West Memphis Arkansas · filed 2010-06-04

The district court also granted summary judgment to the defendants on plaintiffs’ failure to train and failure to supervise claims, holding that such claims could not be sustained absent an underlying constitutional violation by the officer. We agree.

A school board can be liable under § 1983 for failing to train or supervise employees when that failure amounts to deliberate indifference and causes a constitutional violation.

Sagan v. Sumner County Board of Education · filed 2010-07-06

The Court construes these allegations as adequately stating facts which, if proved, would permit a jury to conclude that the Board’s training of other teachers in detecting and reporting abuse was inadequate under the circumstances; that the Board’s failure to recognize or respond to reports of abuse amounted to deliberate indifference; and that there is a causal link between the municipality’s failure to train or supervise and the alleged constitutional violation.

A school board may be liable under § 1983 for failure to train or supervise employees when that failure amounts to deliberate indifference to constitutional rights.

Marcum v. Board of Education of Bloom-Carroll Local School District · filed 2010-07-23

Absent any evidence of a widespread or persistent pattern or practice of constitutional violations, Plaintiffs have failed to present sufficient evidence from which a reasonable jury could find the requisite deliberate indifference. The Board of Education is therefore entitled to summary judgment on Plaintiffs’ § 1983 claim of failure to train and supervise.

Section 1983 does not impose municipal liability for failure to train or supervise a person the municipality never employed.

Banker v. County of Livingston · filed 2011-04-06

Applying these principles, the Complaint fails to plausibly state a municipal liability claim against the County based on a failure to train or supervise, since the County never employed Hanglow.

A city's complete failure to train and supervise officers can constitute a policy supporting municipal liability under § 1983.

Campbell v. City of Springboro, Ohio · filed 2011-04-26

Under such circumstances, the inadequate training and supervision may be fairly said to represent the policy of the city.

A municipality is liable under § 1983 for failure to train or supervise only when its deliberate indifference causes a constitutional deprivation.

Doe v. City of Demopolis · filed 2011-06-30

As a general proposition, then, Doe’s attempts to hold the City liable under § 1983 on a theory of failure to train or supervise Smith are doomed on their face for want of proof of deliberate indifference. The City was entitled to rely on the common sense of Smith and other police officers not to sexually assault children, and therefore was not bound to provide training or supervision to them on that point.

A county’s failure to train or supervise jail staff does not establish § 1983 liability without evidence of deliberate indifference to the need for better training or supervision.

Pauls v. Green · filed 2011-09-07

On this record, there is insufficient evidence for a jury to conclude that Adams County was on notice that more or different training or supervision was necessary to prevent jailers from sexually assaulting inmates.

Section 1983 requires evidence of a municipal policy or custom reflecting deliberate indifference to constitutional rights to hold a city liable for failing to train or supervise its officers.

Rawlings v. District of Columbia · filed 2011-10-28

Because the plaintiff has failed to provide evidence upon which a reasonable jury could find a policy of deliberate indifference toward unjustified police shootings on the part of the District of Columbia, plaintiffs negligent training and supervision claim under Section 1983 cannot survive summary judgment.

A school district is not liable under § 1983 for failure to train or supervise when the alleged constitutional violations did not occur.

Frudden v. Pilling · filed 2012-01-31

A Monell-type failure-to-train-and-supervise claim is not plausible in this case, because the constitutional claims themselves fail.

Section 1983 liability for failure to supervise requires inadequate supervision, deliberate indifference to constitutional rights, and a direct causal link to the alleged deprivation.

Hunter v. Hamilton County Board of Elections · filed 2012-02-08

To succeed on this claim, Plaintiffs must show (1) that the Board failed to adequately train or supervise poll workers; (2) that the failure to train or supervise amounted to a deliberate indifference to the rights of voters; and (3) that there is a direct causal link between the failure to train or supervise and the alleged constitutional deprivation.

A municipality is liable under § 1983 for failing to train or supervise an officer only if that failure caused a rights violation and amounted to deliberate indifference.

Posos v. City of San Antonio · filed 2012-02-28

To prevail on this theory, Posos must show that (1) the SADP either failed to supervise or train Ramos; (2) a causal link exists between the failure to train or supervise and the violation of her rights; and (3) the failure to train or supervise amounts to “deliberate indifference” to her constitutional rights.

Municipal liability under § 1983 for failure to train or supervise ordinarily requires a pattern of similar constitutional violations that puts the municipality on notice of the need for action.

Olaniyi v. District of Columbia · filed 2012-07-11

In sum, Olaniyi has not shown a pattern of unconstitutional forced medications at the D.C. Jail that a reasonable jury could find put the District on notice that either more training or enhanced supervision was necessary to prevent the specific constitutional violation at issue.

Section 1983 permits a claim against a municipality for inadequate training or supervision when the inadequacy results from deliberate indifference and causes the injury.

Russell Marcilis, II v. Township of Redford · filed 2012-09-06

To prevail “on a failure to train or supervise claim, the plaintiff must prove the following: (1) the training or supervision was inadequate for the tasks performed; (2) the inadequacy was the result of the municipality’s deliberate indifference; and (3) the inadequacy was ... closely related to or actually caused the injury.” Id.

Section 1983 failure-to-train and failure-to-supervise claims against a school board require an underlying constitutional violation.

Sagan v. Sumner County Board of Education · filed 2012-10-05

And without a constitutional •violation, appellants cannot establish their failure-to-train and failure-to-supervise claims against Sumner.

Section 1983 permits a claim against a city when its failure to train or supervise employees amounts to an official policy or custom.

Chavez v. City of New York · filed 2012-10-25

The amended pleading sufficiently alleges that the City’s purported failure to train or supervise its employees was tantamount to an official policy or custom under the standards of 42 USC § 1983 (see Johnson v Kings County Dist. Attorney’s Off., 308 AD2d 278, 293-294 [2d Dept 2003]; Walker v City of New York, 974 F2d 293 [2d Cir 1992], cert denied 507 US 961 [1993]).

Section 1983 permits municipal liability for inadequate training or supervision when that policy causes a constitutional violation.

Clyce v. Hunt County Texas · filed 2013-03-04

Municipalities may be liable under § 1983 if a “policy” of inadequate training or supervision caused the violation of the plaintiff’s constitutional rights.

Section 1983 does not support a policy or custom claim based on inadequate training or supervision without an underlying deprivation of a federally protected right.

Amick v. Ohio Department of Rehabilitation & Correction · filed 2013-03-27

If the mental health care givers did not deprive Amick of a federally protected civil right, then their actions are not actionable as a deprivation pursuant to policy or custom.

Section 1983 liability for failure to train or supervise municipal employees requires deliberate indifference to the rights of people those employees encounter.

Salahuddin Smart v. Borough of Bellmawr · filed 2013-06-17

Liability under § 1983 for failure to train or supervise municipal employees requires a showing that the failure amounts to “deliberate indifference” to the rights of persons with whom those employees will come into contact.

A § 1983 failure to train or supervise claim against a supervisor fails if the plaintiff cannot establish deliberate indifference.

Young v. Akal · filed 2013-12-02

Because the Court concludes plaintiffs fail to establish deliberate indifference, the Court need not address the other two prongs of supervisor liability, and the inquiry ends at this stage.

Section 1983 failure-to-train or failure-to-discipline claims against an entity require evidence of a policy or custom and an identified policy-maker.

Lawson v. SPCA · filed 2015-08-19

Plaintiffs have not submitted any evidence to - support their claims against Defendant Pennsylvania SPCA, indicated what policy or custom caused the alleged failure to train or discipline,'identified a policy-maker, or formulated any argument against Defendants’ Motion for Summary Judgment as to that claim. Accordingly, Defendants are entitled to summary judgment as to Plaintiffs’ failure to train and failure to discipline claims.

Section 1983 does not permit liability for inadequate training, monitoring, or supervision without an underlying constitutional violation.

L.H. v. Pittston Area School District · filed 2015-09-10

Because A.H. was not deprived of a constitutional right, the plaintiffs cannot recover from the School District defendants under § 1983 on a theory that they failed to train, monitor dr supervise its employees.

A private medical contractor may be liable under § 1983 for failing to train jail nurses when the risk of constitutional violations is obvious, even without a prior pattern of violations.

Shadrick v. Hopkins Cnty., Kentucky · filed 2015-11-06

A jury could find that “the unconstitutional consequences of failing to train” are “so patently obvious” that SHP should be held “liable under § 1983 without proof of a pre-existing pattern of violations.”

Section 1983 requires factual allegations supporting a municipality’s deliberate indifference to plead a failure-to-train or failure-to-supervise claim.

Jiang v. Porter · filed 2015-12-28

In the absence of factual allegations to support plaintiffs legal conclusions, there is no basis to hold the City of St. Louis liable under § 1983. As a result, plaintiffs claim in Count XI will also be dismissed for failure to state a claim.

Section 1983 permits a failure-to-train claim against a supervisor only when the failure amounts to deliberate indifference to others’ rights and causes the plaintiff’s injury.

Estate of Jason Jerry Owens v. Geo Group, Inc. · filed 2016-08-25

Notably, a supervisory official is not liable under § 1983 for failure to train unless: (1) his failure to train amounts to deliberate indifference of the rights of persons his subordinates come into contact with; and (2) the failure has actually caused the injury of which the plaintiff complains.

A municipality’s failure to train or supervise can support § 1983 liability when it has notice that its training or supervision is deficient.

B.A. v. Manchester School Dist., et al. · filed 2017-07-18

Deliberate indifference for purposes of showing an official policy not to train or supervise requires notice that the training or supervision is deficient. ... As such, the facts allow a reasonable inference that Lubelczyk had notice that Varney required training and supervision to avoid abusing her students, including J.F., but failed to provide either.

Section 1983 requires evidence that a prison healthcare provider’s failure to adopt a needed policy or to train or supervise staff amounts to deliberate indifference before the provider can be held liable.

Ponzini v. PrimeCare Medical, Inc. · filed 2017-08-30

The evidence Plaintiffs presented at trial, viewed in the light most favorable to them, makes clear that no reasonable jury could find Prime-Care liable under § 1983 for failure to adopt a needed policy, or failure to train and supervise its employees and agents.

In a § 1983 claim alleging municipal failure to train or supervise, prior incidents must be highly similar to be relevant.

Williams v. City of Birmingham · filed 2018-04-04

Indeed, courts demand a high degree of factual similarity between prior incidents and the episode involving the plaintiff for the former to be relevant to § 1983 liability for an alleged failure to train or supervise.

A Section 1983 claim against a city for inadequate training or supervision requires evidence sufficient for a jury to find municipal liability.

Parker v. City of Tulsa · filed 2018-08-22

Likewise, no jury could conclude, especially given the complete absence of evidence indicating a pattern of tortious conduct, that Tulsa failed to adequately train or supervise Berry.

Section 1983 generally requires a pattern of similar constitutional violations to support a municipal claim for failure to train or supervise.

Leibel v. City of Buckeye · filed 2019-01-30

C.L. similarly fails to allege that the City is liable under § 1983 for failing to train or supervise Officer Grossman. ... Because C.L. has not alleged a pre-existing pattern of violations, C.L. has not stated a claim for failure to train or supervise against the City.

Section 1983 requires a plaintiff claiming municipal liability for failure to train or supervise to plausibly allege inadequate training, deliberate indifference, and a resulting constitutional injury.

Elbert v. City of Kansas City Missouri · filed 2019-03-26

In considering Plaintiff’s pro se status and viewing all doubts in the Complaint in favor of Plaintiff, the Court finds that Plaintiff has not sufficiently alleged a failure to train or supervise claim under 42 U.S.C. § 1983 in accordance with Rule 12(b)(6).

Section 1983 failure-to-train, supervision, and discipline claims fail when the plaintiff has no underlying constitutional claim.

Belezos v. Board of Selectmen of Hingham, Massachusetts · filed 2019-03-29

Lastly, the dismissal on the merits of the substantive due process claims also includes the failure to train, supervise, and discipline claims.

A school district is liable under § 1983 for failure to train or supervise only if the failure amounts to deliberate indifference to constitutional rights.

Doe v. Fort Zumwalt R-Ii Sch. Dist. · filed 2019-04-11

To hold the District liable under § 1983, Doe must prove that the District’s failure to supervise and train “amounts to deliberate indifference to the rights of persons with whom [Hansen came] into contact.” City of Canton v. Harris, 489 U.S. 378, 388 (1989). ... Without notice, the District’s failure to provide more training or supervision is not deliberately indifferent.

Section 1983 requires deliberate indifference to support municipal liability for a failure to train or supervise employees.

Hardman v. Roosevelt City · filed 2019-06-24

Thus, absent allegations that Roosevelt City was aware of unconstitutional conduct of a similar type alleged here, prior to Mr. Hardman’s interrogation and prosecution, Mr. Hardman cannot establish the “deliberate indifference” required for a municipal liability claim based on an alleged failure to train or supervise.

Section 1983 requires a plaintiff claiming municipal liability for inadequate training or supervision to show deliberate indifference, but does not require an unconstitutional policy or custom.

Forrest v. Parry · filed 2019-07-10

On the other hand, a plaintiff advancing a claim predicated on a municipality’s failure or inadequacy in training, supervision, or otherwise is spared from demonstrating the existence of an unconstitutional policy or custom but must make the deliberate indifference showing.

Section 1983 requires facts showing deliberate indifference and causation to hold a private employer liable for failing to train its employees.

Dawson v. Westchester County · filed 2019-07-29

To state a claim for municipal liability based on failure to train, Plaintiff must allege facts which support an inference that Aramark failed to train its employees, that it did so with deliberate indifference, and that the failure to train caused his constitutional injuries.

A § 1983 failure-to-train claim requires evidence that inadequate training caused or was closely related to the injury.

Stewart v. Warren County Board of Commissioners · filed 2019-09-04

Furthermore, even if the Plaintiff could prove that Solutions’ training program and supervision were inadequate for the tasks Epling and Randol were required to perform and the inadequacy resulted from Solutions’ deliberate indifference, the Plaintiff would still have to offer evidence that “the inadequacy actually caused, or is closely related to,” Justin’s death. Shadrick, 805 F.3d at 738. Plaintiff is unable to do so.

Section 1983 permits a claim against a school district for failure to train or supervise when the district is deliberately indifferent to known or obvious consequences.

Nation v. Piedmont Schools Board of Education · filed 2019-09-17

The Court finds Plaintiffs’ allegations sufficient with regard to municipal liability under a failure to train or supervise theory in light of Plaintiff’s allegation that the District had actual knowledge of Defendant Morris’s actions but failed to act to protect the students.

Section 1983 requires facts showing inadequate municipal training or supervision, deliberate indifference, and a causal link to the constitutional deprivation.

Rose v. City of Saint Louis, Missouri · filed 2019-09-23

To state a viable claim under § 1983 for failure to train or supervise, Plaintiff must plead facts sufficient to establish: (1) the City’s officer-training and supervision practices were inadequate; (2) the City was deliberately indifferent to the rights of others in adopting these practices, such that the City’s failure to train and supervise resulted from deliberate and conscious choices it made; and (3) the City’s alleged training and supervision deficiencies caused Plaintiff's constitutional deprivation.

Section 1983 does not impose municipal liability for failure to train or supervise when the officers committed no underlying constitutional violation.

Bond v. Tahlequah, City of · filed 2019-09-25

Likewise, without a constitutional violation, the claim of failure to train and supervise fails. Graves v. Thomas, 450 F.3d 1215, 1218 (10th Cir.2006). Summary judgment is appropriate on this basis.

Section 1983 permits a pro se inmate’s municipal failure-to-train claim to proceed despite sparse factual allegations when the supporting facts would be difficult to gather before discovery.

Hardie v. City of Albany · filed 2019-10-25

But even though Hardie’s complaint is lacking in factual allegations to support this claim, the Second Circuit instructs the district courts to read a pro se plaintiff’s complaint liberally, see Lopez v. Jet Blue Airways, 662 F.3d 593, 596 (2d Cir. 2011), and it would be very difficult for Hardie as a pro se inmate to gather the necessary facts to support his claim at this early stage in the litigation—before discovery has even begun. Defendants’ motion to dismiss as it pertains to Hardie’s Monell claim is therefore denied.

Section 1983 does not permit municipal liability for failure to train or supervise when no officer committed an underlying constitutional violation.

Claro v. Sulphur, City of · filed 2019-12-16

Because this Court found (above) that there was no constitutional violation by Defendants Medina, LaFountain, Odom (all SPD officers), or McClure (an MCSO deputy), neither the City nor the Board may be held liable for failure to train or supervise, and therefore they are both entitled to summary judgment on Plaintiff’s Third Cause of Action.

Section 1983 requires facts supporting deliberate indifference to constitutional rights to state a municipal failure-to-supervise claim.

STOKES v. PRICE · filed 2019-12-17

Plaintiff’s complaint does not contain any facts suggesting the Prosecutor’s Office was deliberately indifferent to his constitutional rights. The conclusory statement that the Prosecutor’s Office was “aware” of Detective Price’s investigation does not support a plausible inference that it failed to supervise him.

Section 1983 permits a municipal liability claim for failure to train, supervise, or discipline officers when the complaint plausibly alleges a policy or practice that caused the misconduct.

Mabb v. The Town of Saugerties · filed 2020-01-14

The Court finds that, when viewing all of the factual allegations in the complaint as true and in the light most favorable to Plaintiff, he has adequately pled a cause of action for § 1983 municipal liability against Defendants Ulster County and the Town of Saugerties for failure to train, supervise, or discipline Defendants Mullen and Hampel.

Section 1983 permits municipal liability for a failure to train or supervise only when the failure meets the deliberate indifference standard and causes the injury.

Roberts v. Coffee County, Tennessee · filed 2020-01-16

Accordingly, Coffee County cannot be held liable under § 1983 based on a failure to train or supervise theory.

A § 1983 claim for municipal failure to train or supervise requires deliberate indifference and a causal link between the deficiency and the injury.

ELLIS v. CITY OF PHILADELPHIA · filed 2020-02-10

In addition to deliberate indifference, the Plaintiff must also be able to establish a causal nexus between the injury and the alleged deficient training or supervision.

Section 1983 liability for deficient training or supervision requires deliberate indifference and a causal link to the injury.

Perez v. Ryan · filed 2020-03-02

Here, Plaintiff has not attempted to identify the ways in which the Defendants’ training or supervision was purportedly inadequate, much less presented evidence to show that any such failure was both deliberately indifferent and the cause of the injuries he suffered at the hands of front-line correctional officers.

A supervisor may be individually liable under § 1983 for failure to train if the failure shows deliberate indifference and actually causes a constitutional deprivation.

McGuire v. Cooper · filed 2020-03-06

A supervisor’s failure to train an inferior officer may also give rise to individual liability under § 1983 if (1) “the failure to train amounts to deliberate indifference to the rights of persons with whom the police come into contact,” Parrish, 594 F.3d at 1002 (quoting Otey v. Marshall, 121 F.3d 1150, 1156 (8th Cir. 1997)), and (2) “the alleged failure to train ‘actually caused’ the constitutional deprivation.” ... Sheriff Dunning is entitled to qualified immunity in his individual capacity.

Section 1983 liability for failure to train or supervise requires widespread abuse and a causal link between the supervisory failure and the constitutional injury.

Canter v. Shoppert · filed 2020-03-09

Although these factual allegations could plausibly raise an inference that Defendants Bishop, Bohrer, and Moyer knew about the specific incident involving the feed-up slot, they are not sufficient to support an inference that there was widespread abuse of constitutional rights among their subordinates. Moreover, Plaintiff has failed to allege any facts that would support a causal link between alleged deficiencies in training and supervision on the part of Defendants Bishop, Bohrer, and Moyer, and the excessive force, deliberate indifference, and retaliation injuries suffered by Plaintiff.

Section 1983 requires a plaintiff alleging municipal failure to train or supervise to plausibly show deliberate indifference and a causal connection to the constitutional injury.

Pettiford v. The City of Yonkers · filed 2020-04-27

Furthermore, there is no new evidence that meets the “stringent standard” that any alleged failure to train or supervise was done with a “deliberate indifference,” or that these failures caused Plaintiff’s specific constitutional violation.

Section 1983 requires evidence of notice of similar constitutional violations and deliberate indifference to support a municipal failure-to-train or supervise claim.

Bosarge v. Mobile Area Water & Sewer Service · filed 2020-05-29

However, Plaintiff’s cited instances do not show Defendants were on notice of a deficiency in training or supervision from similar constitutional violations nor has Plaintiff shown a pattern of similar constitutional violations. Therefore, Plaintiff fails to demonstrate deliberate indifference as required.

Section 1983 requires an underlying constitutional violation for a claim based on inadequate training or supervision.

Alexander v. Beach · filed 2020-05-29

In the absence of an underlying constitutional violation, Plaintiff cannot maintain a cause of action for inadequate training or supervision.

A Section 1983 failure-to-train or supervisory-liability claim requires an underlying constitutional violation.

A.H. v. County of Tehama · filed 2020-08-04

Without a constitutional violation, Plaintiffs have no claim against anyone, including the County, Department, Hencratt, and Johnston.

Section 1983 failure-to-train and supervisory-liability claims require an underlying constitutional violation by the officer.

Browning v. Edmonson County, Kentucky · filed 2020-08-13

Because Plaintiffs are unable to demonstrate that Jones violated their Fourteenth Amendment rights as it pertains to the pursuit, Plaintiffs’ failure to train and supervise claims against Doyle and Edmonson County will be dismissed with prejudice, as well.

Section 1983 failure-to-train or supervise claims require an underlying constitutional violation.

Torres v. Livingston · filed 2020-08-25

Because Torres does not allege facts that amount to a constitutional violation, his claims of failure to train or supervise, against the other defendants, also necessarily fail.

A § 1983 failure-to-train claim against a parish can proceed without a pattern of violations when inmate abuse is a highly predictable consequence of the lack of training.

Thompson v. France · filed 2020-09-28

Accordingly, due to the high potential for various sorts of abuse, the Court agrees with Plaintiff that abuse of inmates was a highly predictable consequence of Tangipahoa Parish’s failure to train Mr. France. Therefore, Tangipahoa Parish’s motion to dismiss Plaintiff’s § 1983 claim should be denied.

Section 1983 requires factual allegations connecting a supervisor’s policy or failure to train to a risk of constitutional injury; conclusory allegations are insufficient.

BROOKINS v. WETZEL · filed 2020-10-08

Brookins has only made conclusory failure to train allegations. The bare allegations, without further explanation, are insufficient to plausibly allege that there was a specific policy or custom regarding the destruction of inmate property during the move to SCI Phoenix that created an unreasonable risk of constitutional injury.

Section 1983 permits supervisory liability for failure to train only when the supervisor knew the inadequate training was likely to lead to constitutional violations.

ROSS v. LOOP · filed 2020-11-02

Supervisors may be liable under § 1983 for a failure to train in limited circumstances. The plaintiff must show that the defendant knew that his failure to train was likely to lead to constitutional violations. ... Here, because Ross has failed to show that Bush violated his constitutional rights, he has failed to support a claim that Loop failed to train him.

Section 1983 does not impose liability for failure to train or supervise when no constitutional right was violated.

Saxon v. City of Dillon · filed 2020-12-30

In the absence of a constitutional right violation, which did not occur, neither the City of Dillon nor Guiberson can be held liable under 42 U.S.C. § 1983.

Section 1983 requires proof of discriminatory purpose or intent for a racial-discrimination claim.

Ganguly v. New York State Department of Mental Hygiene-Dunlap Manhattan Psychiatric Center · filed 1981-03-25

Liability under § 1983 for racial discrimination requires proof of discriminatory purpose or intent.

Section 1983 permits students to bring claims for unconstitutional racial discrimination in a school district’s employment of teachers and administrators, but they must show discriminatory intent as well as disparate impact.

Castaneda v. Pickard · filed 1981-06-23

Thus, we think that the class of plaintiffs here may also assert a cause of action based upon unconstitutional racial discrimination in employment of teachers and administrators under 42 U.S.C. § 1983. ... Thus, discriminatory intent, as well as disparate impact, must be shown in employment discrimination suits brought against public employers under Title VI, 42 U.S.C. § 1981 or § 1983.

Section 1983 does not provide relief for a public-employment equal-protection claim without proof that the challenged classification was motivated by discriminatory intent.

Briggs v. City of Madison · filed 1982-05-07

In this instance, where I have found that plaintiffs failed to establish proof of intentional sex discrimination under Title VII, plaintiffs cannot rely on their Title VII claim to establish the requirement of discriminatory purpose. Plaintiffs do not offer any other argument, or cite any other evidence, to demonstrate that a discriminatory purpose influenced the City’s classification practice, and I am not aware of any evidence in the record that demonstrates such a purpose. Indeed, the impediment to plaintiffs’ equal protection claim is similar to the impediment to plaintiffs’ Title VII claim: plaintiffs are unable to implicate the City in an unlawful employment practice or in discriminatory purpose. In the absence of the latter showing, I cannot conclude that the defendant has violated the equal protection clause. ... Accordingly, I find that plaintiffs have failed to state a claim for relief under § 1983 or the Fourteenth Amendment.

A § 1983 employment-discrimination claim requires proof of discriminatory purpose, and an unimplemented comparable-worth study alone does not establish that purpose.

AMERICAN NURSES'ASS'N v. State of Ill. · filed 1985-04-04

Plaintiffs make no other argument nor cite any other evidence to demonstrate that a discriminatory purpose influenced the State's classification practice. Accordingly, plaintiffs have failed to state a claim for relief under § 1983 or the Fourteenth Amendment, as well as under Title VII.

A jury’s discrimination finding on jointly tried sections 1981 and 1983 claims collaterally estops the parties on the same issue in a Title VII claim because the claims require the same elements of proof.

Slaughter v. City of Maplewood · filed 1985-07-05

As discrimination claims brought under § 1981, § 1983 and Title VII require the same elements of proof, ... this Court concludes that it is bound by the jury’s finding that defendant did not discriminate against plaintiff.

Section 1983 does not make an employer liable for simply erroneous or arbitrary decisions.

Friedel v. City of Madison · filed 1987-10-13

Neither sections 1981 and 1983 nor Title VII makes an employer liable for simply erroneous or arbitrary decisions.

A § 1983 employment-discrimination claimant must prove that the public employer intentionally treated the claimant less favorably because of sex.

Catlett v. Missouri Highway & Transportation Commission · filed 1987-10-23

To prevail under section 1983 the individuals and the class had to prove Missouri intentionally treated them less favorably because of their sex.

A § 1983 equal-protection claim for racial discrimination in employment requires proof that the employer acted with a racially discriminatory purpose.

Aguirre-Molina v. New York State Division of Alcoholism & Alcohol Abuse · filed 1987-11-12

an individual seeking relief under § 1983 for alleged racial discrimination in employment in violation of her equal protection rights must prove that the employer was motivated by a racially discriminatory purpose.

Section 1983 does not provide a claim for employment practices that are cognizable only under Title VII, which requires exhaustion of its administrative processes.

Heath v. Louisville & Jefferson County Metropolitan Sewer Dist. · filed 1989-04-05

Likewise, plaintiff's employment related claims filed under 42 U.S.C. Secs. 1983 and Sec. 1985 were properly dismissed because such claims, which essentially allege unlawful employment practices, are only cognizable in Title VII actions, following exhaustion of the administrative processes of Title VII.

Section 1983 employment discrimination claims are evaluated using the principles applied in Title VII cases.

Senigaur v. Beaumont Independent School District · filed 1991-04-03

In examining this claim under the 14th Amendment and 42 U.S.C. §§ 1981 and 1983, this court is to apply the principles articulated in Title VII cases.

Section 1983 employment discrimination claims are analyzed under the same framework as Title VII claims.

Blount v. Alabama Cooperative Extension Service · filed 1994-10-06

Discrimination claims brought under 42 U.S.C. §§ 1981 and 1983 are analyzed under the same framework as Title VII claims.

Section 1983 employment discrimination claims based on circumstantial evidence use the same prima facie analysis as Title VII claims.

Philippeaux v. County of Nassau · filed 1996-04-10

Although the defendants specifically refer only to plaintiffs Title VII claims as the subject of their application, the Court observes that the analysis for determining whether the plaintiff has established a prima facie case of discrimination through circumstantial evidence ... is the same ... under Title VII as it is under the following additional statutes pursuant to which he seeks relief: 42 U.S.C. §§ 1981 and 1983, and the Age Discrimination in Employment Act, 29 U.S.C. § 621 et seq.

Section 1983 remains available for constitutional employment discrimination claims against municipalities and their employees despite Title VII and § 1981 remedies under the Civil Rights Act of 1991.

Johnson v. City of Fort Lauderdale · filed 1997-05-30

For these reasons, we conclude that the Civil Rights Act of 1991 did not render Title VII and § 1981 the exclusive remedies for employment discrimination by a municipality and its employees, thereby preempting a constitutional cause of action under § 1983.

Section 1983 covers employment discrimination by an employer acting under color of state law, and a discrimination claim has the same elements as a Title VII claim.

Rice-Lamar v. City of Fort Lauderdale · filed 1998-11-25

Discrimination is also unlawful under 42 U.S.C. § 1983, where the employer is also acting under color of state law. The Court notes that the elements of a Title VII claim and a section 1983 claim for discrimination are the same.

Employment discrimination claims under § 1983 use the Title VII evidentiary framework.

Lawrence v. University of Texas Medical Branch at Galveston · filed 1999-01-05

Employment discrimination claims brought under 42 U.S.C. §§ 1981, 1983, and 2000d are analyzed under the evidentiary framework applicable to claims arising under Title VII of the Civil Rights Act of 1964, as amended at 42 U.S.C. § 2000e et seq.

Section 1983 employment-discrimination claims use the same analytical framework as Title VII claims.

Butt v. Board of Trustees of Eastern Illinois University · filed 1999-06-15

The analytical framework for a Title VII claim is the same as for Sections 1981 and 1983 claims (42 U.S.C. §§ 1981, 1983).

Section 1983 equal protection employment discrimination claims use the Title VII proof scheme established in McDonnell Douglas.

Demesme v. Montgomery County Government · filed 1999-08-12

While the plaintiff has brought his claim as a direct constitutional violation under the Fourteenth Amendment and § 1983, the Title VII proof scheme adopted by the Supreme Court in McDonnell Douglas v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973) applies.

Section 1983 employment discrimination claims based on the same conduct as Title VII claims use the same elements and evaluative framework.

Pennington v. City of Huntsville, Ala. · filed 2000-04-24

The elements and evaluation of section 1981 and section 1983 claims are identical to the elements and evaluative structure found in Title VII cases.

Section 1983 employment discrimination claims use Title VII's burden-shifting framework.

Hajjar v. Dayner · filed 2000-05-03

In analyzing a discrimination claim under section 1983, courts borrow the burden-shifting framework of Title VII claims set out in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802, 93 S.Ct. 1817, 1824, 36 L.Ed.2d 668 (1973).

Section 1983 claims of race or gender discrimination have the same elements as Title VII disparate treatment claims.

Rice-Lamar v. City of Ft. Lauderdale · filed 2000-11-08

The elements of a section 1983 claim of race or gender discrimination are the same as the elements of a Title VII disparate treatment action.

Section 1983 permits an employment discrimination claim without a concurrent Title VII claim or compliance with Title VII’s procedural requirements.

Padilla v. Harris · filed 2003-09-30

A plaintiff may, as here, bring a claim for employment discrimination under 42 U.S.C. § 1983 without concurrently pleading a violation of Title VII and satisfying the procedural requirements of that statute.

Section 1983 employment discrimination claims alleging equal protection violations use the same analytical procedure as Title VII and ADEA claims.

Kearney v. County of Rockland · filed 2005-06-15

Employment discrimination claims brought pursuant to 42 U.S.C. § 1983 to vindicate alleged violations of the Equal Protection Clause are evaluated under the same analytical procedure as claims brought under Title VII and the ADEA.

Section 1983 employment discrimination claims brought under the Equal Protection Clause are evaluated under the same standard as Title VII claims.

Sharif v. Buck · filed 2005-10-17

Employment discrimination actions brought as equal protection claims under 42 U.S.C. § 1983 are subject to the same evaluation as Title VII claims.

A § 1983 employment discrimination claim based on circumstantial evidence is analyzed under the McDonnell Douglas framework.

Drakeford v. Alabama Cooperative Extension System · filed 2006-02-06

The Plaintiff alleges that the Defendants violated Title VII and § 1983 by discriminating against him on the basis of his race. Because the Plaintiff relies entirely upon circumstantial evidence to support his discrimination claims, the court’s analysis will be guided by the three-step framework established in McDonnell Douglas Corp. v. Green, 411 U.S. 792, 93 S.Ct. 1817, 36 L.Ed.2d 668 (1973).

Section 1983 employment race discrimination claims are analyzed under the Title VII disparate treatment framework.

Elam v. BOARD OF TRUSTEES OF UNIVERSITY OF DC · filed 2007-12-18

Similarly, federal claims of race discrimination in the employment context brought under § 1981 and § 1983 are also resolved under the same Title VII principles.

Section 1983 employment discrimination claims may be analyzed under the Title VII framework.

Oakley v. City of Memphis · filed 2008-09-08

The district court properly applied the Title VII framework to Plaintiffs’ claims under 42 U.S.C. §§1981, 1983, and the Tennessee Human Rights Act, Tenn. Code Ann. §4-21-401.

Section 1983 employment discrimination claims based on the same facts as Title VII claims have the same elements.

Gray v. Vestavia Hills Bd. of Education · filed 2008-12-02

The district court did not err by granting the Board’s motion for summary judgment on Gray’s § 1983 claims because, discussed supra, Gray failed either to: (1) establish prima facie cases for her Title VII claims; or (2) demonstrate pretext as to the Board’s proffered legitimate, nondiscriminatory reasons for her failure to promote and disparate pay claims.

Section 1983 requires specific facts supporting a claim against the defendants independent of employment discrimination allegations against another employer.

Ronsonet v. Carroll · filed 2000-01-03

The plaintiff failed to assert any specific facts against the federal defendants that would support a section 1983 action against them that are independent of her employment discrimination allegations against the BHA.

Section 1983 racial discrimination and retaliation claims against a government employer are analyzed under the same standards as Title VII claims.

Davis v. Dallas Independent School District · filed 2011-11-04

Because a claim of racial discrimination under Section 1983 is “essentially the same” as such a claim brought under Title VII, our analysis with respect to Davis’s discrimination and retaliation claims applies with equal force to both causes of action.

Section 1983 can support an age discrimination claim based on equal protection, but a violation of an employment discrimination statute alone cannot support a claim.

Thomas v. New York City Department of Education · filed 2013-03-29

A plaintiff can bring an equal protection claim based on age discrimination, but cannot use violations of employment discrimination statutes as the basis for a § 1983 claim.

Section 1983 discrimination claims seeking the same relief as Title VII claims have the same elements and use the same analytical framework.

Haugabrook v. Cason · filed 2013-05-10

The district court recognized that Haugabrook sought the same relief for alleged Title VII violations as she did under 42 U.S.C. §§ 1983 and 1981. For that reason, the court correctly concluded that the elements of the claims were the same and the same analytical framework applied.

Section 1983 employment discrimination claims must be brought against individual government officers and supported by facts plausibly linking the challenged conduct to discriminatory intent.

Cole v. Board of Trustees of Northern Illinois University · filed 2014-08-05

Disparate treatment and retaliation claims based on a violation of the Equal Protection Clause in the employment context pursuant to § 1983 are identical to Title VII claims in all relevant aspects, ... except that (1) Title VII claims are brought against an employer while § 1983 claims must be brought against an individual government officer and, more importantly, (2) conclusory allegations of the causative link are not sufficient, instead plaintiff must offer “facts that might plausibly support” the discriminatory intent link.

When § 1983 provides a parallel remedy against an individual for an underlying Title VII violation, the equal protection claim has the same elements as the Title VII claim.

English v. Board of School Commissioners · filed 2015-01-27

In the context of evaluating an equal protection claim, when § 1983 is used as a parallel remedy against an individual for an underlying violation of Title VII, the elements of the two causes of action are the same.

Section 1983 employment discrimination claims have the same elements as Title VII claims when both arise from the same facts.

Johnny L. Griffin v. The City of Demorest · filed 2015-12-22

Our analysis of Griffin’s Title VII and § 1983 claims is the same because they are based on the same set of facts, so the elements of the claims are the same.

Section 1983 employment discrimination claims use the McDonnell Douglas three-step burden-shifting framework.

Johnson v. New York City Department of Education · filed 2016-02-18

When analyzing a discrimination claim under Title VII, 42 U.S.C. § 1983, or 42 U.S.C. § 1981, we employ a three-step burden-shifting analysis derived from McDonnell Douglas Corporation v. Green, 411 U.S. 792, 802 (1973).

Section 1983 race-based employment discrimination and harassment claims use the same analytical frameworks as corresponding Title VII claims.

Moss v. Texarkana Arkansas School District · filed 2017-03-01

Claims of race-based employment discrimination filed under § 1983 are analyzed under the same framework as Title VII claims. ... Title VII and § 1983 harassment claims are likewise analyzed under the same framework. ... Based on this, and in light of the Court’s above rulings with respect to Plaintiffs Title VII race-discrimination and harassment claims, her § 1983 claims against Defendants must also fail as a matter of law.

Section 1983 permits Equal Protection Clause claims against individual government employees alongside Title VII and ADEA claims.

Robert C. Mills v. Indiana Department of Child Services, Shirley Starks, Kristen L. Sparks, Melanie Reising, and Elizabe · filed 2017-04-28

Given that § 1983 permits Equal Protection Clause claims against individual government employees, that § 1983 claims can be brought simultaneously with Title VII and ADEA claims, and that the trial court failed to explain its ruling, we agree with Mills that the court erred when it disposed of his claims against Starks, Sparks, Reising, and Herrmann for allegedly violating his rights under the Equal Protection Clause.

Section 1983 discrimination claims based on § 1981 or the Equal Protection Clause use the same proof standards and analytical framework as Title VII intentional discrimination claims.

McQueen v. Alabama Department of Transportation · filed 2019-04-23

Discrimination claims brought under § 1983 based on § 1981 and the Equal Protection Clause are subject to the same standards of proof and use the same analytical framework as intentional discrimination claims brought under Title VII.

Section 1983 employment discrimination claims require the plaintiff to show that the employer’s stated nondiscriminatory reason is false or insufficient to support the adverse action.

Clay v. The County of Suffolk · filed 2019-09-11

In other words, a § 1983 [or ADA] plaintiff must establish that the employer’s stated non-discriminatory reason is either false or inadequate to support the adverse employment action.

Section 1983 employment discrimination claims alleging an equal protection violation may be analyzed under the McDonnell Douglas burden-shifting framework.

Kenny v. University of Delaware · filed 2019-11-08

Plaintiffs also allege Defendants are liable under 42 U.S.C. § 1983 for depriving them of their Fourteenth Amendment rights to equal protection. ... Given there is no dispute between the parties on this question, I apply the McDonnell Douglas analysis to both the statutory and constitutional sexual orientation discrimination claims.

Section 1983 employment discrimination and retaliation claims may be analyzed under the McDonnell Douglas burden-shifting framework.

Bangura v. Commonwealth of PA Senate · filed 2019-12-03

The District Court properly analyzed Bangura’s remaining discrimination claims, and her retaliation claims, according to the burden-shifting framework established by McDonnell Douglas Corp. v. Green, 411 U.S. 792, 802 (1973). See Jones v. Sch. Dist. of Phila., 198 F.3d 403, 410 (3d Cir. 1999) (explaining that the framework generally applies to claims under Title VII, the PHRA, and 42 U.S.C. § 1981); Stewart v. Rutgers, The State Univ., 120 F.3d 426, 432 (3d Cir. 1997) (applying the framework to claims under 42 U.S.C. § 1983).

Section 1983 employment discrimination claims use the same burden-shifting framework as Title VII claims.

Bresilien v. City of New York · filed 2020-03-17

Section 1983 claims asserting employment discrimination use the same burden-shifting framework developed by the Supreme Court for Title VII claims.

Section 1983 sex discrimination claims are evaluated under the same standards as Title VII claims.

Purtue v. Wisconsin Department of Correc · filed 2020-06-26

We evaluate Pur- tue’s § 1983 claims under the same standards as her Title VII claims, so they stand or fall together.

Section 1983 permits challenges to civil commitment statutes seeking declaratory and prospective injunctive relief; release from confinement may require habeas proceedings.

Karsjens v. Jesson · filed 2014-08-11

The Court recognizes that while some injunctive relief may ultimately be awarded to both the class and individual members of the class, ultimate release from the detention at the MSOP may be required through habeas or procedures that may be - mandated under 42 U.S.C. § 1983. Civil rights actions such as this one are an appropriate vehicle for challenges to civil commitment statutes, and declaratory and prospective injunctive reliefs are available in such cases.

Section 1983 permits a challenge to civil commitment hearing procedures when success would provide a new hearing without necessarily ending or shortening the commitment.

Aruanno v. New Jersey · filed 2007-02-02

Instead, he only seeks a new civil commitment hearing. Pursuant to Wilkinson, Aruanno’s claims are cognizable under § 1983.