Board Of The County Commissioners Of Bryan County v. Brown

520 U.S. 397 (1997)

Purchase the Printed Copy at bsmsphd.com

Nature of the Case

To access this section all you need to do is click here and register.

Facts

P and her husband were driving to their home. After crossing into Oklahoma, they approached a police checkpoint. Mr. Brown, who was driving, decided to avoid the checkpoint and return to Texas. After seeing the Browns' truck turn away from the checkpoint, Deputy Sheriff Robert Morrison and Reserve Deputy Stacy Burns pursued the vehicle. Both deputies claimed that their patrol car reached speeds in excess of 100 miles per hour. Mr. Brown testified that he was unaware of the deputies' attempts to overtake him. The chase finally ended four miles south of the police checkpoint. Deputy Sheriff Morrison pointed his gun toward the Browns' vehicle and ordered the Browns to raise their hands. Reserve Deputy Burns, who was unarmed, rounded the corner of the vehicle on the passenger's side. Burns twice ordered P from the vehicle. When she did not exit, he used an 'arm bar' technique, grabbing P's arm at the wrist and elbow, pulling her from the vehicle, and spinning her to the ground. P's knees were severely injured, and she later underwent corrective surgery. Ultimately, she may need knee replacements. P sued under 42 U.S.C. § 1983 and state law seeking damages from Ds (Burns, Bryan County Sheriff B. J. Moore, and the county itself). P claimed that D was liable for Burns' alleged use of excessive force based on Sheriff Moore's decision to hire Burns, the son of his nephew. P claimed that Sheriff Moore had failed to adequately review Burns' background. Burns had a record of driving infractions and had pleaded guilty to various driving-related and other misdemeanors, including assault and battery, resisting arrest, and public drunkenness. Sheriff Moore testified that he had obtained Burns' driving record and a report on Burns from the National Crime Information Center, but had not closely reviewed either. Sheriff Moore authorized Burns to make arrests, but not to carry a weapon or to operate a patrol car. D moved for judgment as a matter of law. D argued that a single hiring decision by a municipal policymaker could not give rise to municipal liability under §1983. The District Court denied D's motions. In answering several interrogatories the jury concluded that Stacy Burns had arrested P without probable cause and had used excessive force, and therefore found him liable for P's injuries. It also found that the 'hiring policy' and the 'training policy' of D 'in the case of Stacy Burns as instituted by its policymaker, B. J. Moore,' were each 'so inadequate as to amount to deliberate indifference to the constitutional needs of P.' Judgment was entered against D. The Court of Appeals held that D was properly found liable under §1983 based on Sheriff Moore's decision to hire Burns. It did not address the jury's determination of county liability based on inadequate training of Burns. The Supreme Court granted certiorari.