The police killing of George Floyd in Minneapolis sparked national protests calling for major police practice reforms. An area of particular concern is the adequacy and effectiveness of police training in the use of force. It is reasonable to expect that better trained and supervised law enforcement officers will be more circumspect in employing deadly and other types of force. This column examines the remedy offered by 42 U.S.C. §1983 against municipalities based upon inadequate training of their police officers.

Supreme Court decisions authorize §1983 municipal liability based upon deliberately indifferent training policies and practices. Connick v. Thompson, 563 U.S. 51 (2011); City of Canton v. Harris, 489 U.S. 378 (1989). As we will see, the decisions in Connick and City of Canton place very heavy burdens on §1983 plaintiffs seeking to impose municipal liability based upon inadequate training.