Springfield v. Kibbe

480 U. S. 257

February 25, 1987

A very ineptly conducted car chase ended with a police officer shooting the suspect dead after a few feeble attempts at roadblocks failed. Kibbe, the administratrix of the victim’s estate, argued that inadequate training of police forces caused the suspect’s death, and that the municipality could be sued in a section 1983 action. The Supreme Court granted certiorari to decide if inadequate training could be the basis for a 1983 suit, and to determine what amount of negligence would be required to find such liability if it existed.

After granting certiorari, the Court discovered that the parties had not devoted much attention to the standard of negligence question in the litigation below. For that reason, the Court dismissed the writ of certiorari as improvidently granted in a 5-4 per curiam opinion. O’Connor, joined by Rehnquist, White, and Powell, dissented from this dismissal. She argued that the Court of Appeals had discussed the level of negligence question, and that this was enough to allow the Court to pass on it even if the parties were uninterested. Moving to the merits, she held that a municipality could be held liable for inadequate training under section 1983, but only if there was a clear showing of deliberate indifference to the rights of suspects – which is to say gross negligence at a minimum. O’Connor felt this heightened standard was necessary to insure strong causality. Examining the facts before her, she could not say that the police showed deliberate indifference, and thus rejected Kibbe’s claim.

Here’s another case where the Supreme Court avoided a decision on the basis of some stupid justiciability principle. I completely agree with O’Connor that the Court should have decided the case. Punting in cases like this only causes thousands of dollars to be wasted on further judicial proceedings toward the end of finally getting an answer out of the Supreme Court. With regard to the merits, O’Connor makes a good case, but I find myself wanting to hear the other side. Sadly, the five Justice majority deprived me of any chance to hear it.

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